Dear [ ]:
You have requested a ruling on behalf of your client, [ ], regarding one of its customers, [ ]. [ ] requests a ruling pursuant to 31 CFR 103.81 that [ ] be considered neither a “foreign shell bank,” nor a “foreign bank” for purposes of 31 CFR 103.175 and 103.177, or, alternatively…
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The Financial Crimes Enforcement Network (FinCEN) continued its examination of terrorist financing methods in the fifth issue of The SAR Activity Review – Trends, Tips and Issues just released today. This latest issue of The Review looks…