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FinCEN Publishes Five Rulings on the Application of Money Transmission Definitions and Exemptions to Certain Business Models
Monday, May 12, 2014 6:55 AM

The Financial Crimes Enforcement Network (FinCEN) has published five administrative rulings, providing additional information on how exemptions from money transmitter status may or may not apply to certain business models, under the 2011 modifications to the Bank Secrecy Act’s (BSA) definition of a money transmitter.

Following are the five rulings:

  • FIN-2014-R008: Whether a Company that Provides an Armored Car Coin and Currency Exchange Service is a Money Transmitter and Whether the Armored Car Service Exemption Would Apply to the Service
  • FIN-2014-R007: Application of MSB regulations to the rental of computer systems for mining virtual currency
  • FIN-2014-R006: Whether a Company that Provides Online Real-Time Deposit, Settlement, and Payment Services for Banks, Businesses and Consumers is a Money Transmitter rather than a Provider of Prepaid Access
  • FIN-2014-R005: Whether a Company that Offers Secured Transaction Services to a Buyer and Seller in a Given Sale of Goods or Services is a Money Transmitter
  • FIN-2014-R004: Application of MSB Regulations to a Company that Offers Escrow Services to a Buyer and Seller in a Given Internet Sale of Goods or Services

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