Regulatory Alerts2014-04-29
FinCEN Administrative Ruling on Armored Car Coin and Currency Exchange Service Money Transmitter Status
The Financial Crimes Enforcement Network issued an administrative ruling determining that a company providing an armored car coin and currency exchange service is not a money transmitter under the Bank Secrecy Act. FinCEN concluded that the service does not constitute money transmission because the company retains ownership of the currency throughout the exchange process, effectively acting as a remote teller rather than accepting and transmitting value from one person to another. Additionally, the ruling specifies that the armored car service exemption does not apply because the activity involves changing denominations rather than solely transporting currency.
Share