Administrative Rulings

Administrative letter rulings drafted by the Financial Crimes Enforcement Network (FinCEN) are issued pursuant to our authority as the administrator of the Bank Secrecy Act, if the facts and circumstances, issues, and analyses that appear in an administrative letter ruling are of general interest to financial institutions then the letter ruling is published on our website. Published letter rulings often express an opinion about a new issue; apply an established theory or analysis to a set of facts that differs materially from facts or circumstances that have been previously considered; or provide a new interpretation of Title 31 of the United States Code, or any other statute granting FinCEN authority. A summary of the variety of regulatory releases, which also includes an outline of the effect of the various releases on financial institutions that are subject to the regulatory provision at issue, is available here [HTML | PDF]

| Depository Institutions

The Financial Crimes Enforcement Network (FinCEN) is issuing this ruling to provide exceptive relief to covered financial institutions with respect to the application of the Beneficial Ownership Requirements for Legal Entity Customers (31 CFR § 1010.230) (Beneficial Ownership Rule) to premium…

| Money Services Businesses

 

Dear []:

This responds to your letter of July 15, 2014, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), regarding FinCEN’s money services business (“MSB”) regulations under the Bank Secrecy Act (“BSA…

| Money Services Businesses

 

Dear [ ]:

This responds to your letter of December 3, 2013, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), about the Company’s possible status as a money services business (“MSB”) under the Bank…

| Money Services Businesses

 

Dear [ ]:

This responds to your letter of January 6, 2014, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), about the Company’s possible status as a money services business (“MSB”) under the Bank Secrecy…

| Money Services Businesses

 

The Financial Crimes Enforcement Network (“FinCEN”) is issuing this administrative ruling (the “CT Ruling” or “this Ruling”) to clarify the application of FinCEN regulations to certain persons involved in transportation of currency. Currency transporters who engage in transactions that…

| Money Services Businesses

 

Dear [ ]:

This responds to your letter of March 18, 2014, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of [ ] (the “Company”), about the Company’s possible status as a money services business (“MSB”) under the Bank Secrecy…

| Money Services Businesses

 

Dear [ ]:

This responds to your letter of December 4, 2012, seeking an administrative ruling from the Financial Crimes Enforcement Network (“FinCEN”) on behalf of your client, [the Company], regarding whether your client is a money services business (“MSB”) under FinCEN’s…