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…
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Dear [ ]:
This letter responds to your letter dated November 21, 2002, requesting a determination with respect to whether [ ], a subsidiary of [ ], is a Money Services Business (“MSB”) for purposes of regulations implementing the Bank Secrecy Act (“BSA”) found at 31 CFR Part 103. [ ] is…