Regulatory Alerts2003-10-20
Added
FinCEN Ruling 2003-9 – Definition of Money Services Business (Money Transmitter/Currency Dealer or Exchanger)
FinCEN determined that an individual transporting their own currency from Colombia to the United States for personal profit is not required to register as a money services business under 31 CFR 103.41. This exemption applies because the individual is exchanging and transporting their own money on their own behalf, rather than acting as a money transmitter or currency dealer for others. FinCEN clarified that it lacks jurisdiction over state-imposed licensing requirements and advised the individual to consult relevant state banking departments regarding Florida or other state license obligations.
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