Administrative Rulings

Pursuant to its authority at 31 CFR Part 1010 Subpart G, the Financial Crimes Enforcement Network (FinCEN) may issue administrative rulings interpreting the Bank Secrecy Act (BSA) or FinCEN’s implementing regulations at 31 CFR Chapter X. Administrative rulings that are published on FinCEN’s website provide guidance to financial institutions and other requestors in complying with applicable BSA regulations. Published administrative rulings have precedential value and may be relied upon by others that are similarly situated. FinCEN does not respond substantively to every request for an administrative ruling and reserves the right to decline to provide a ruling to any request. Administrative ruling requests must be made in accordance with the requirements set out at 31 CFR 1010.711 and may be submitted to administrative.rulings@fincen.gov.

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

Dear [ ]:

This responds to your letter of December 3, 2013, 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 (“…

| Money Services Businesses
Administrative Ruling on the Application of FinCEN Regulations to Currency Transporters, Including Armored Car Services, and Exceptive Relief

 

The Financial Crimes Enforcement Network (“FinCEN”) is issuing this administrative ruling (the “CT Ruling” or “this Ruling”) to clarify the application of FinCEN regulations to certain persons involved in transportation of currency. Currency transporters who engage in transactions…

| Money Services Businesses
Application of Money Services Business Regulations to a Company Acting as an Independent Sales Organization and Payment Processor

Dear [ ]:

This responds to your letter of March 18, 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…

| Money Services Businesses
Whether a Company that Provides an Armored Car Coin and Currency Exchange Service is a Money Transmitter and Whether the Armored Car Service Exemption Would Apply to the Service

Dear [ ]:

This responds to your letter of December 4, 2012, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of your client, [the Company], regarding whether your client is a money services business (“MSB”) under FinCEN’s regulations.…

| Money Services Businesses
Application of Money Services Business Regulations to a Company that Offers Escrow Services to a Buyer and Seller in a Given Internet Sale of Goods or Services

Dear [ ]:

This responds to your letter of October 25, 2013, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), about the Company’s status as a money services business (“MSB”) under the Bank Secrecy Act (“BSA”).…

| Money Services Businesses
Whether a Company that Offers Secured Transaction Services to a Buyer and Seller in a Given Sale of Goods or Services is a Money Transmitter

Dear [ ]:

This responds to your letter of August 9, 2013, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), about the Company’s status as a money services business (“MSB”) under the Bank Secrecy Act (“BSA”).…

| Depository Institutions, Money Services Businesses
Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather

Dear [ ]:

This responds to your letter dated August 21, 2012 on behalf of [ ] (the “Company”) to the Financial Crimes Enforcement Network (“FinCEN”), in which you seek an administrative ruling on the application of money services business (“MSB”) regulations as they relate to the…

| Money Services Businesses
Application of Money Services Business regulations to the rental of computer systems for mining virtual currency

Dear [ ]:

This responds to your letter mailed to us on February 26, 2014, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) regarding the status of [ ] (the “Company”) as a money services business (“MSB”) under the Bank Secrecy Act (“BSA”).…

| Money Services Businesses
FinCEN Issues Ruling on Records to be Made and Maintained by Dealers in Foreign Exchange

 

The Financial Crimes Enforcement Network (“FinCEN”) is issuing this administrative ruling to clarify circumstances in which a dealer in foreign exchange may accept alternative travel documents as identification for a non-resident alien.1

Background…

| Money Services Businesses
Application of FinCEN’s Regulations to Virtual Currency Mining Operations

Dear [ ]:

This responds to your letter of June 1, 2013, 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”).…