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FIN-2008-R008Issued: June 3, 2008Subject: Bank Secrecy Act Obligations of a U.S. Clearing Broker-Dealer Establishing a Fully Disclosed Clearing Relationship with a Foreign Financial Institution
Dear [ ]:
I am responding to your letters dated September 14, 2005, and March 21 and May 3, 2006, requesting an administrative ruling as to whether [ ], which serves as an authorized agent for the receipt of utility payments, is a money services business as that term is defined in our regulations.1 Specifically, this ruling addresses whether [ ] is a money transmitter.2
I am responding to your request for an administrative ruling, dated June 12, 2007, on behalf of [ ] (the "Company") to the Financial Crimes Enforcement Network ("FinCEN"). You have requested a ruling regarding whether the Company is a money services business, as that term is defined in our regulations.1
