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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…
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 at…