Regulatory Alerts2008-03-18
Added
Ruling on Whether a Foreign Exchange Dealer is a Currency Dealer or Exchanger or Money Transmitter
FinCEN determines that a foreign exchange company conducting electronic transactions is a currency dealer or exchanger if it exchanges funds denominated in U.S. currency for foreign currency in amounts greater than $1,000 for any person on any day. The ruling further classifies the company as a money transmitter because its acceptance and transmission of funds to third-party foreign counterparts is not an integral part of the execution and settlement of the transaction itself. These classifications apply to the specific activities described for the client company under 31 C.F.R. § 103.11(uu).
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