Regulatory Alerts2011-03-10
Added
FinCEN Ruling on Definition of Currency for CMIR Reporting
FinCEN clarifies that Canadian Silver Maple Leaf coins are not automatically reportable on FinCEN Form 105 unless they satisfy the three-part regulatory definition of currency. The ruling establishes that persons transporting such items must apply public information to determine if the coins constitute currency under 31 CFR § 103.11(h). If the items do not meet this definition, no other report is required under the Bank Secrecy Act, though other federal regulations may apply. The document does not provide case-by-case confirmations for individual coin types but directs entities to use available public data for compliance determinations.
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