Regulatory Alerts2008-03-18
Added
Ruling on Whether Foreign Exchange Risk Management Entities Are Currency Dealers or Money Transmitters
The Financial Crimes Enforcement Network determines that a company engaged in foreign exchange risk management for internet sellers is a currency dealer or exchanger if it exchanges funds denominated in different currencies in amounts greater than $1,000 on any day. The entity is classified as a money transmitter because it settles supply transactions by moving funds between clients and suppliers through its own accounts, which does not constitute an integral part of executing or settling a transaction other than the funds transmission itself. The request for regulatory relief is denied because the company offers cross-border transactional services that may be exploited by financial criminals engaged in money laundering and terrorist financing.