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Q. Broker-dealers engage in transactions through omnibus accounts and sub-accounts established by financial intermediaries. In these situations, (1) the omnibus account or relationship is established by or on behalf of a financial intermediary for the purpose of executing transactions that will…

Dear [ ]: This is in response to your letter of May 19, 2003 to the Financial Crimes Enforcement Network ("FinCEN") requesting guidance as to whether your client, who provides funds for business operating capital to customers, may file Currency Transaction Reports (“CTRs”) on behalf of the client’s…

Dear [ ]: This letter responds to your letter dated November 21, 2002, requesting a determination with respect to whether [ ], a subsidiary of [ ], is a Money Services Business (“MSB”) for purposes of regulations implementing the Bank Secrecy Act (“BSA”) found at 31 CFR Part 103. [ ] is licensed…