January 2008

By The Numbers Issue 9

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Sigue Corp. and Sigue, LLC of California to Pay $15 Million to U.S. Government for Anti-Money Laundering Program Deficiencies

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Reporting of Certain Currency Transactions for Sole Proprietorships and Legal Entities Operating Under a “Doing Business As” (“DBA”) Name

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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

FinCEN Names Peter Goodyear as Associate Director for Analysis and Liaison

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Whether a Business that Cashes Checks Payable to Customers to Apply Proceeds to the Repayment of Customers’ Obligations is a Money Services Business

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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, and therefore that it is not required to register with the Financial Crimes Enforcement Network (FinCEN).

Whether a Publicly Traded Company that Cashes its own Checks Issued to Loan Customers is a Money Services Business

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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.