Regulatory Alerts2008-03-19
Added
Ruling on Whether a Foreign Exchange Consultant is a Currency Dealer or Exchanger or Money Transmitter
FinCEN determines that an intermediate foreign exchange broker and consultant acting as an intermediary between clients and executing banks is not a currency dealer, exchanger, or money transmitter under 31 C.F.R. § 103.11(uu). The entity does not qualify as a currency dealer because it does not exchange currency itself; the transactions are effected by the executing bank. Furthermore, the entity is not a money transmitter because any funds it accepts and transmits to the executing bank constitute an integral part of settling the foreign exchange transaction rather than serving as a funds transmission service.
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