Regulatory Alerts2014-03-11
FinCEN Issues Ruling on Records to be Made and Maintained by Dealers in Foreign Exchange
The Financial Crimes Enforcement Network issued an administrative ruling to clarify that dealers in foreign exchange may accept alternative U.S.-issued travel documents as valid identification for non-resident aliens. This exception allows dealers to record the number and description of these alternate entry documents instead of a foreign passport when verifying customer identity for transactions exceeding $1,000. The ruling specifically addresses recordkeeping requirements and does not alter the obligation to file suspicious activity reports for transactions lacking a lawful business purpose.
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