Regulatory Alerts2005-06-24
Added
Definition of Money Services Business (Ceasing to be a Money Services Business)
FinCEN determines that a bank is not required to treat a customer as a money services business if that customer ceases to offer check cashing services meeting the $1,000 definitional threshold under 31 CFR 103.11(uu)(2). A business that develops and implements written policies to exclude itself from the definition of a money services business is not subject to Bank Secrecy Act requirements for such entities, even if its FinCEN registration has not yet expired. This ruling applies to entities that no longer engage in activities triggering the money services business classification, such as check cashing above the specified daily aggregate limit.