• FinCEN Rulings on Foreign Exchange Activities
  • June 12, 2008
  • Law Firm: Alston & Bird LLP - Atlanta Office
  • Three recent letter rulings from the Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") provide guidance with respect to the facts and circumstances pursuant to which FinCEN will determine that an entity is acting as a "Currency Dealer or Exchanger" or "Money Transmitter," within the scope of 31 C.F.R. ยง 103.11(uu) (defining "Money Services Businesses").