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Frequently Asked Questions Anti-Money Laundering Program and Suspicious Activity Reporting Requirements for Insurance Companies

This guidance originally was issued on October 31, 2005. We have updated the guidance provided in these frequently asked questions at question 7, further coordinating the answer with guidance provided in the final anti-money laundering program rule for insurance companies that was published in…

Whether a Foreign Exchange Consultant is a Currency Dealer or Exchanger or Money Transmitter

Dear [ ]:

I am responding to your letter of January 24, 2008 to the Financial Crimes Enforcement Network, requesting a ruling as to whether your company [ ] is a money services business. Specifically, you have asked us to determine whether your company is a currency dealer or exchanger…

Whether a Person That is Engaged in the Business of Foreign Exchange Risk Management is a Currency Dealer or Exchanger or Money Transmitter

Dear [ ]:

I am responding to your letter of September 2, 2005 to [the Financial Crimes Enforcement Network]. You seek a determination as to whether your client, [ ] (the "Company") is a money services business, specifically a currency dealer or exchanger or a money transmitter, as those…

Whether a Foreign Exchange Dealer is a Currency Dealer or Exchanger or Money Transmitter

Dear [ ]:

I am responding to your letter of June 29, 2007 to [the Financial Crimes Enforcement Network]. You have requested a ruling as to whether your client, [Forex Company], is a money services business, specifically a currency dealer or exchanger or a money transmitter, as those…

Whether Certain Reloadable Card Operations are Money Services Businesses

This letter is in response to a request from [Service Company], a subsidiary of [Parent], dated June 6, 2007, to the Financial Crimes Enforcement Network (FinCEN) for an administrative ruling concerning the treatment under the Bank Secrecy Act (BSA) provisions applicable to money services…

Guidance for Dealers, Including Certain Retailers, of Precious Metals, Precious Stones, or Jewels, on Conducting a Risk Assessment of Their Foreign Suppliers

The Financial Crimes Enforcement Network ("FinCEN") is issuing this guidance clarifying the risk assessment required to be performed under the Interim Final Rule requiring anti-money laundering programs for dealers in precious metals, precious stones, or jewels ("Interim Final Rule").1…

PREPARED REMARKS OF JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK

Good morning ladies and gentlemen. It is a real pleasure for me to be with you here at this Jewelers Vigilance Committee AML seminar. This is a great opportunity for us to engage in a fruitful dialogue about still relatively new anti-money laundering responsibilities for the dealer industry.…

PREPARED REMARKS OF JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK

Good morning. I am delighted to be here this morning to help kick-off SIFMA’s Anti-Money Laundering Compliance Conference for 2008. I would like to thank Alan Sorcher of SIFMA, who has been a leader on AML issues for broker-dealers since we commenced with the USA PATRIOT Act rulemakings. I am…

Customer Identification Program Rule No-Action Position Respecting Broker-Dealers Operating Under Fully Disclosed Clearing Agreements According to Certain Functional Allocations

In the securities brokerage industry, certain broker-dealers ("introducing firms") enter into clearing agreements with other broker-dealers ("clearing firms") according to the provisions of the rules of a broker-dealer self-regulatory organization, which permit the introducing firm and clearing…

PREPARED REMARKS OF JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK

Good morning. I would like to thank Clemente Vazquez-Bello for his kind introduction. I’d also like to thank Pat Roth for her leadership within the Florida International Bankers Association and for inviting me to speak with all of you today at the 8th Annual Florida International Bankers…