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Dear [ ]: This is in response to your e-mail requesting clarification regarding whether Currency Transaction Reports (“CTRs”) must be filed with respect to specific types of transactions conducted by money transmitters and/or their agents. In your e-mail, you presented the following scenario:…

 

Dear [ ]: You have requested a ruling on behalf of your client, [ ], regarding one of its customers, [ ]. [ ] requests a ruling pursuant to 31 CFR 103.81 that [ ] be considered neither a “foreign shell bank,” nor a “foreign bank” for purposes of 31 CFR 103.175 and 103.177, or, alternatively, that…