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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.
FIN-2008-R001
Issued: January 25, 2008
Subject:Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a "Doing Business As" ("DBA") Name
The Financial Crimes Enforcement Network ("FinCEN") is issuing this administrative…
Dear [ ]:
This letter responds to your request for an administrative ruling, dated June 16, 2007, regarding whether your client, [ ], should be registered as a money services business (MSB). For the reasons set forth below, we have determined that your client's business is not an MSB,…
Dear [ ]:
I am responding to your letter, dated July 5, 2007, to the Financial Crimes Enforcement Network. You have asked us to determine whether [ ] (the "Company") is a money services business, specifically a check casher as that term is defined in our regulations.
As you…
Dear [ ]: This letter responds to your letter dated [ ] to the Internal Revenue Service (IRS) [Enterprise Computing Center - Detroit], which was referred to the Financial Crimes Enforcement Network ("FinCEN") for response on [ ]. In your letter, you ask why [your business] is not listed on…
Dear [ ]: I am writing in response to your letter of June 7, 2006 to the U.S. Department of the Treasury, in which you request an administrative ruling on behalf of [ ] that addresses whether the Bank Secrecy Act and its implementing regulations require corporate credit unions to file Currency…
Dear [ ]:
I am writing in response to your letter of November 18, 2004 to the Financial Crimes Enforcement Network requesting, on behalf of the [Regulatory Office], an administrative ruling that interprets the Bank Secrecy Act requirement to report casino currency transactions in excess of $…
Dear [ ]:
This letter responds to your letters, dated November 15, 2005 and January 25, 2006, in which you request guidance in the form of an administrative ruling on the proper completion of the Currency Transaction Report, FinCEN Form 104, when reporting a transaction made by or on behalf…
Dear [ ]:
I am writing in response to your December 21, 2005 e-mail to Director Fox and Deborah Silberman, requesting on behalf of your clients that we hold implementation of our interim final rule regarding dealers in precious metals, stones or jewels1 in abeyance for persons…
Dear [ ]:
Thank you for your letter requesting our views concerning the extent to which financial institutions must establish programs to review currency transactions to detect and report “structuring” when the conduct does not require the filing of a currency transaction report. You also…
Dear [ ]:
I write in response to your letter of June 6, 2005 to the Financial Crimes Enforcement Network, in which you request guidance on whether casinos must comply with rules under the Bank Secrecy Act specific to money services businesses. Casinos and card clubs, as defined in our…