2012-05-23

Added

Application of the Money Services Business Rule to a Bank Holding Company that Issues Official Checks

FinCEN rules that a bank holding company issuing official checks is not a money services business under its regulations. The determination relies on the finding that these instruments do not meet the definition of traveler's checks because they lack a required countersignature, nor are they classified as money orders due to distinct regulatory authorizations and face value limits. Consequently, the issuance of such checks does not trigger money services business status for the holding company.

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Financial Crimes Enforcement Network

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