Regulatory Alerts2004-03-29
Added
Definition of Money Services Business (Foreign-Located Currency Exchanger With U.S. Bank Account)
FinCEN determined that a foreign-located currency exchanger maintaining only a U.S. bank account is not required to register as a Money Services Business under 31 C.F.R. § 103.41. The ruling concludes that the U.S. account does not constitute an agent, agency, branch, or office within the United States because the entity conducts all currency exchange and funds transmission activities exclusively in the foreign country. Consequently, the entity is not subject to MSB registration requirements despite the existence of the U.S. financial institution account.
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