Dear [ ]:
This letter responds to your request for an administrative ruling, dated April 21, 2005, with respect to whether [the business] is a money services business for purposes of regulations implementing the Bank Secrecy Act found at 31 CFR Part 103, and if so, which regulations apply to…
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]
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Dear [ ]:
This responds to your letters to the Financial Crimes Enforcement Network (“FinCEN”) of March 18, 2005, and June 14, 2005, requesting a determination as to whether (“bank”) must continue to treat its customer (“business”), which is currently registered as a money services business…
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Dear [ ]:
This is in response to e-mail correspondence your employee, [ ], sent to the Financial Crimes Enforcement Network (“FinCEN”) on December 2, 2004 expressing concern about the discontinuance of banking services to money services businesses. FinCEN shares this concern about the…
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Dear [ ]:
This letter responds to your letters, dated June 18, 2004 and December 7, 2004, to the Financial Crimes Enforcement Network (“FinCEN”). In your letters, you request, on behalf of [Casino] and [Casino] (each a “Casino”), an administrative ruling that interprets 31 C.F.R. § 103.22(c…
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Dear [ ]:
This letter responds to your letter dated June 16, 2004, requesting a determination as to whether your client, [the business], is a money services business (“MSB”) for purposes of regulations promulgated by the Financial Crimes Enforcement Network (“FinCEN”), under the Bank Secrecy…
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Dear [ ]:
This letter responds to your request for an administrative ruling with respect towhether your client, [ ], is required to register with FinCEN as a Money ServicesBusiness (“MSB”) pursuant to 31 C.F.R. § 103.41. Pursuant to 31 CFR § 103.82,FinCEN declined to provide [ ] with such a…
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Dear [ ]:
This letter responds to your letter dated April 19, 2004, to FinCEN’s Office of Regulatory Policy, Programs and Enforcement, in which you request guidance on the proper completion of FinCEN Form 104. Financial institutions other than casinos complete FinCEN Form 104 when reporting…
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Dear [ ]:
This letter responds to your letter dated January 8, 2004, requesting a determination as to whether your client, [ ], a [foreign] currency exchanger with its principal place of business in [a foreign country], is required to register with the Financial Crimes Enforcement Network (“…
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Dear [ ]:
This letter responds to your letter dated February 5, 2003, requesting an administrative ruling with respect to whether [ ] is required to register with FinCEN as a Money Services Business in accordance with 31 CFR 103.41 by virtue of operating [ ]. Based on the representations…
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Dear [ ]:
This letter responds to your letter dated July 8, 2003, requesting an administrative ruling with respect to whether your client, [ ], is required to register with FinCEN as a Money Services Business in accordance with 31 CFR 103.41. FinCEN had previously declined to provide [ ]…