April 2003

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 scenario:

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, that it receive an exemption from the requirements of these rules.