Regulatory Alerts2014-09-24
Administrative Ruling on the Application of FinCEN Regulations to Currency Transporters, Including Armored Car Services, and Exceptive Relief
The Financial Crimes Enforcement Network (FinCEN) issued this administrative ruling to clarify the application of Bank Secrecy Act regulations to currency transporters, including armored car services, by defining specific exemptions from money transmitter status. The ruling establishes that transporters are exempt when acting under the direction of federally regulated financial institutions or when performing direct point-to-point physical transport without subcontracting or taking more than a custodial interest. For transactions falling outside these exemptions, currency transporters are deemed money transmitters and must comply with full anti-money laundering, recordkeeping, and reporting obligations, including a new conditional exception for certain wholly domestic shipments.