Regulatory Alerts2013-11-13
Administrative Ruling on Whether a Company Offering Payable-Through Drafts is a Money Transmitter
The Financial Crimes Enforcement Network (FinCEN) issued this administrative ruling to determine if a company offering a payment mechanism based on payable-through drafts constitutes a money services business. FinCEN concluded that the company is a money transmitter because it accepts funds from customers and transmits them to merchants, and the activity does not qualify for exemptions as an integral part of other services or as a payment processor. Consequently, the company must register with FinCEN and comply with all applicable Bank Secrecy Act recordkeeping and reporting requirements.
Share