Regulatory Alerts2003-10-28
Added
Definition of Money Transmitter (Armored Car Companies)
FinCEN provides general guidance on whether armored car companies are money services businesses under 31 CFR 103.11(uu). An armored car business is not a money transmitter if it transports funds for or to a U.S. financial institution, or if it merely performs secure physical transportation without participating in the financial transaction. However, the business is deemed a money transmitter if it transports funds to a third-party beneficiary or if it exercises authority over exchange rates or institutions during currency exchange services.