Dear [ ]:
This letter responds to your July 14, 2003 letter on behalf of [ ] and [ ], requesting an administrative ruling with respect to whether either party, [ ] or [ ], is a Money Services Business (“MSB”) as defined in 31 CFR 103.11(uu), and therefore subject to the MSB registration…
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 letter responds to your October 6, 2003 letter requesting an administrative ruling with respect to whether you are required to obtain a license or to register because you transport your own currency from Colombia into the United States. Based on the representations contained…
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Dear [ ]:
This is in response to your letter of May 19, 2003 to the Financial Crimes Enforcement Network ("FinCEN") requesting guidance as to whether your client, who provides funds for business operating capital to customers, may file Currency Transaction Reports (“CTRs”) on behalf of the…
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Dear [ ]:
This letter responds to your letter dated November 21, 2002, requesting a determination with respect to whether [ ], a subsidiary of [ ], is a Money Services Business (“MSB”) for purposes of regulations implementing the Bank Secrecy Act (“BSA”) found at 31 CFR Part 103. [ ] is…
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Dear [ ]:
This is in response to your e-mail requesting clarification regarding whether Currency Transaction Reports (“CTRs”) must be filed with respect to specific types of transactions conducted by money transmitters and/or their agents.
In your e-mail, you presented the following…
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Dear [ ]:
You have requested a ruling on behalf of your client, [ ], regarding one of its customers, [ ]. [ ] requests a ruling pursuant to 31 CFR 103.81 that [ ] be considered neither a “foreign shell bank,” nor a “foreign bank” for purposes of 31 CFR 103.175 and 103.177, or, alternatively…
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Dear [ ]:
This responds to your email dated July 11, 2002, regarding the aggregation of currency transactions pursuant to 31 CFR § 103.22. You have asked whether the transactions described below must be aggregated for purposes of filing a currency transaction report (“CTR”).
Agent “A…
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Dear [ ]:This letter responds to your letter to Judith R. Starr, Chief Counsel of the Financial Crimes Enforcement Network (“FinCEN”) dated December 14, 2001, in which you seek, on behalf of [ ], interpretive guidance regarding application of the Bank Secrecy Act (“BSA”), 31 U.S.C. 5311-5331,…
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Dear [ ]:
This responds to your letter of September 26, 2001, on behalf of [ ] (the 'Bank'), to the Internal Revenue Service-Enterprise Computing Center-Detroit (IRS), regarding the requirement to file Currency Transaction Reports (CTRs) in accordance with the Bank Secrecy Act (BSA), 31…
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This ruling, formerly known as 92-1, was posted to the website on May 18, 2010; it was previously published via the Federal Register. Please note that references in this ruling to CTR form numbers are outdated.
Facts:
31 U.S.C. 5313 -- Reports on Domestic Coins and Currency…