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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]
Dear [ ]:
I am responding to your letter, dated May 12, 2008, to the Financial Crimes Enforcement Network (“FinCEN”), in which you seek an administrative ruling…
FIN-2008-R010Issued: December 11, 2008Subject: Whether a Company that Engages in Certain Operations as an Authorized Agent for Collection of Social Security and Veteran Benefits is a Money Services Business
Dear [ ]:
This responds to your initial letter of December 11,…
Dear [ ]:
I am responding to your letter, dated September 11, 2007, to the Financial Crimes…
FIN-2008-R008Issued: June 3, 2008Subject: Bank Secrecy Act Obligations of a U.S. Clearing Broker-Dealer Establishing a Fully Disclosed Clearing Relationship with a Foreign Financial Institution
Dear [ ]:
I am responding to your letter of April 15, 2008 to the Financial…
I am responding to your request for an administrative ruling, dated June 12, 2007, on behalf of [ ] (the "Company") to the Financial Crimes Enforcement Network ("FinCEN"). You have requested a ruling regarding whether the Company is a money services business, as that term is defined in our…
I am responding to your letters dated September 14, 2005, and March 21 and May 3, 2006, requesting an administrative ruling as to whether [ ], which serves as an authorized agent for the receipt of utility payments, is a money services business as that term is defined in our regulations.1…
FIN-2008-R005Issued: March 10, 2008Subject: Whether Certain Reloadable Card Operations are Money ServicesBusinesses
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)…
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…
FIN-2008-R002Issued: March 18, 2008Subject: 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…
FIN-2008-R003Issued: March 18, 2008Subject: 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…