Regulatory Alerts2014-04-29
FinCEN Ruling on Whether a Company Providing Online Real-Time Deposit, Settlement, and Payment Services is a Money Transmitter
The Financial Crimes Enforcement Network issued an administrative ruling confirming that a company providing online real-time deposit, settlement, and payment services for banks, businesses, and consumers is classified as a money transmitter rather than a provider of prepaid access. The agency determined that the company's platform facilitates direct fund transfers between designated buyers and sellers without the essential elements of a prepaid program, such as fungible instruments or electronic devices. Consequently, FinCEN concluded that the acceptance and transmission of funds are not integral to any other service and must be registered under the money transmitter category.
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