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May 2012

Application of the Money Services Business Rule to a Bank Holding Company that Issues Official Checks

Financial Crimes Enforcement Network

Ruling

FIN-2012-R001
Issued: May 23, 2012
Subject: Application of the Money Services Business Rule to a Bank Holding Company that Issues Official Checks

Dear [ ]:
This letter responds to your April 8, 2009 request to the Financial Crimes Enforcement Network (“FinCEN”) for an administrative ruling on whether [ ] (the “Company”) is a money services business (“MSB”) as defined in our regulations. [ ]

PREPARED REMARKS OF JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK U.S. DEPARTMENT OF THE TREASURY

I am honored to be here today, and to be a part of this conference’s 20th anniversary. A 20th anniversary is particularly meaningful to me as Director of FinCEN, as our agency celebrated our 20th anniversary only two years ago.

And while the focus of my remarks will be about how the anti-money laundering environment has evolved over these past 20 years, I think it is important to lay the groundwork for our discussions this morning by quickly looking back even further to the beginning.

The Evolution of AML Regulations