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| Guidance
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FinCEN, in consultation with the federal regulatory authorities, has issued a guidance package designed to assist financial institutions in the preparation of Suspicious Activity Report (SAR) forms and to improve the quality of…
| Administrative Ruling
Dear [ ]:
This letter responds to your letter dated July 8, 2003, requesting an administrative ruling with respect to whether your client, [ ], is required to register with FinCEN as a Money Services Business in accordance with 31 CFR 103.41. FinCEN had previously declined to provide [ ] with such…
| Administrative Ruling
Dear [ ]:
This letter responds to your July 14, 2003 letter on behalf of [ ] and [ ], requesting an administrative ruling with respect to whether either party, [ ] or [ ], is a Money Services Business (“MSB”) as defined in 31 CFR 103.11(uu), and therefore subject to the MSB registration requirement…
| Administrative Ruling
Dear [ ]:
This letter responds to your October 6, 2003 letter requesting an administrative ruling with respect to whether you are required to obtain a license or to register because you transport your own currency from Colombia into the United States. Based on the representations contained in your…
| Guidance
Q. Broker-dealers engage in transactions through omnibus accounts and sub-accounts established by financial intermediaries. In these situations, (1) the omnibus account or relationship is established by or on behalf of a financial intermediary for the purpose of executing transactions that will…
| Administrative Ruling
Dear [ ]:
This is in response to your letter of May 19, 2003 to the Financial Crimes Enforcement Network ("FinCEN") requesting guidance as to whether your client, who provides funds for business operating capital to customers, may file Currency Transaction Reports (“CTRs”) on behalf of the client’s…