February 2009
FinCEN Issues Ruling (FIN-2008-R010) on Whether a Company that Engages in Certain Operations as an Authorized Agent for Collection of Social Security and Veteran Benefits is a Money Services Business
FIN-2008-R010Issued: December 11, 2008Subject: Whether a Company that Engages in Certain Operations as an Authorized Agent for Collection of Social Security and Veteran Benefits is a Money Services Business
Dear [ ]:
FinCEN Issues Ruling (FIN-2008-R011) on Whether a Company that Engages in Microfinance is a Money Services Business
FIN-2008-R011Issued: December 11, 2008Subject: Whether a Company that Engages in Microfinance is a Money Services Business
Dear [ ]:
I am responding to your letter, dated May 12, 2008, to the Financial Crimes Enforcement Network (“FinCEN”), in which you seek an administrative ruling as to whether your client, [ ] ( the “Company”), is a money services business, specifically a money transmitter, as that term is defined by our regulations. Additionally, you have asked what provisions of the Bank Secrecy Act apply if the Company is a money services business.