Regulatory Alerts2004-08-17
Added
Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger)
FinCEN determined that the client is not a Money Services Business for Bank Secrecy Act purposes regarding its international courier operations originating or terminating at U.S. financial institutions and its local armored truck transportation services for U.S. customers. FinCEN concluded the client does not qualify as a money transmitter or currency dealer because it acts solely as a physical transporter without participating in or having a financial stake in the underlying transactions. However, FinCEN stated that if the client engages in trans-shipment transactions through the United States, it would be deemed a money transmitter subject to registration requirements.