Regulatory Alerts2012-06-25
Application of Money Services Business Regulations to Daily Money Management Services
The Financial Crimes Enforcement Network issued an administrative ruling determining that a company providing daily money management services constitutes a money transmitter under the Bank Secrecy Act. FinCEN concluded that the company's activities of accepting customer funds and transmitting payments to creditors are not integral to other services, thereby triggering registration, recordkeeping, and reporting obligations. This decision distinguishes the company's operations from previous rulings on debt management and utility payment agents where fund transmission was ancillary to core service provision.
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