Administrative Rulings

Administrative letter rulings drafted by the Financial Crimes Enforcement Network (FinCEN) are issued pursuant to our authority as the administrator of the Bank Secrecy Act, if the facts and circumstances, issues, and analyses that appear in an administrative letter ruling are of general interest to financial institutions then the letter ruling is published on our website. Published letter rulings often express an opinion about a new issue; apply an established theory or analysis to a set of facts that differs materially from facts or circumstances that have been previously considered; or provide a new interpretation of Title 31 of the United States Code, or any other statute granting FinCEN authority. A summary of the variety of regulatory releases, which also includes an outline of the effect of the various releases on financial institutions that are subject to the regulatory provision at issue, is available here [HTML | PDF]

| Securities and Futures
FinCEN Publishes an Administrative Ruling Regarding Customer Identification Program and Customer Due Diligence Requirements for Designated Beneficiaries of Individual Retirement Accounts
| Casinos
Exceptive Relief for Casinos from Certain Customer Identity Verification Requirements
| Casinos, Depository Institutions, Insurance Industry, Money Services Businesses, Mortgage Co/Broker, Precious Metals/Jewelry Industry, Securities and Futures
Rescission of Administrative Ruling Regarding the Participation of Associations of Financial Institutions in the 314(b) Program (December 2020)
| Depository Institutions, Money Services Businesses
FinCEN CTR (Form 112) Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a “Doing Business As” (“DBA”) Name
| Depository Institutions, Securities and Futures
Exceptive Relief from Beneficial Ownership Requirements for Legal Entity Customers of Rollovers, Renewals, Modifications, and Extensions of Certain Accounts
| Depository Institutions, Securities and Futures
Extension of Limited Exception from Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Rollovers and Renewals
| Depository Institutions, Securities and Futures
Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Automatic Rollovers or Renewals
| Depository Institutions
Premium Finance Cash Refunds and Beneficial Ownership Requirements for Legal Entity Customers

The Financial Crimes Enforcement Network (FinCEN) is issuing this ruling to provide exceptive relief to covered financial institutions with respect to the application of the Beneficial Ownership Requirements for Legal Entity Customers (31 CFR § 1010.230) (Beneficial Ownership Rule) to premium…

| Money Services Businesses
Application of FinCEN’s Regulations to Persons Issuing Physical or Digital Negotiable Certificates of Ownership of Precious Metals

 

Dear []:

This responds to your letter of July 15, 2014, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), regarding FinCEN’s money services business (“MSB”) regulations under the Bank Secrecy Act (“…

| Money Services Businesses
Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System

Dear [ ]:

This responds to your letter of January 6, 2014, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), about the Company’s possible status as a money services business (“MSB”) under the Bank Secrecy Act (“BSA…