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May 2008

FinCEN Issues Ruling (FIN-2008-R002) on Whether a Foreign Exchange Dealer is a Currency Dealer or Exchanger or Money Transmitter


FIN-2008-R002Issued: March 18, 2008Subject: Whether a Foreign Exchange Dealer is a Currency Dealer or Exchanger or Money Transmitter

Dear [ ]:

I am responding to your letter of June 29, 2007 to [the Financial Crimes Enforcement Network]. You have requested a ruling as to whether your client, [Forex Company], is a money services business, specifically a currency dealer or exchanger or a money transmitter, as those terms are defined at 31 C.F.R. § 103.11(uu).

FinCEN Issues Ruling (FIN-2008-R004) on Whether a Foreign Exchange Consultant is a Currency Dealer or Exchanger or Money Transmitter

Dear [ ]:

I am responding to your letter of January 24, 2008 to the Financial Crimes Enforcement Network, requesting a ruling as to whether your company [ ] is a money services business. Specifically, you have asked us to determine whether your company is a currency dealer or exchanger or a money transmitter as those terms are defined at 31 C.F.R. § 103.11(uu).1