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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]
Dear [ ]:
This responds to your letters of May 21, 2013 and July 10, 2013, 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”).…
Dear [ ]:
This responds to your letter of October 26, 2012, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of your client, [the Company] regarding the effect your client’s trading in the prepaid access secondary market…
Dear [ ]:
This responds to your letter of October 22, 2007, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on whether your client, [ ] (the “Company”), is a money services business (“MSB”) under the regulations implementing the…
The Financial Crimes Enforcement Network (“FinCEN”) is issuing this administrative ruling in response to issues and concerns related to FinCEN ruling FIN-2009-R002.1 That ruling clarified that, when an armored car service (“ACS”) is contracted to conduct transactions on…
The Financial Crimes Enforcement Network ('FinCEN') is issuing this administrative ruling in response to issues and concerns related to FinCEN ruling FIN-2009-R002.1 That ruling clarified that, when an armored car service ('ACS') is contracted to conduct transactions on behalf of…
Dear []:
This letter responds to your [] request to the Financial Crimes Enforcement Network ("FinCEN") for an administrative ruling on the definition of "association of financial institutions." Specifically, you requested a determination of whether [the Company] would be…
The Financial Crimes Enforcement Network ("FinCEN") is issuing this Ruling to clarify the requirements under FinCEN's regulations for loan and finance companies that are subsidiaries of financial institutions subject to the same regulations applicable to the parent financial institution and…
Financial Crimes Enforcement Network
Ruling
FIN-2012-R004
Issued: May 25, 2012
Subject: Application of Money Services Business Regulations to Daily Money Management Services
Dear [ ]:
This responds to your…
Financial Crimes Enforcement Network
Ruling
FIN-2012-R002
Issued: May 25, 2011
Subject: Definition of Precious Metals in the Interim Final Rule Requiring
Anti-Money Laundering Programs for Dealers in Precious
Metals, Stones, or Jewels…
Financial Crimes Enforcement Network
Ruling
FIN-2012-R003
Issued: May 23, 2012
Subject: Application of the Prepaid Access Rule to Bank-Controlled Programs
Dear [ ]:
I am responding to your letter, dated…