Dealers In Foreign Exchange

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Dealers In Foreign Exchange

Regulation defines a dealer in foreign exchange as a person that accepts the currency, or other monetary instruments, funds, or other instruments denominated in the currency, of one or more countries in exchange for the currency, or other monetary instruments, funds, or other instruments denominated in the currency, of one or more other countries in an amount greater than $1,000 for any other person on any day in one or more transactions, whether or not for same-day delivery.

Money Services Businesses are subject to the full range of BSA regulatory requirements, including the anti-money laundering program rule, suspicious activity and currency transaction reporting rules, and various other identification and record-keeping rules. Existing FinCEN regulations require certain MSBs to register with FinCEN. Many states have established supervisory requirements, often including the requirement that an MSB be licensed with the state(s) in which it is incorporated or does business.

At Gilbert Reese, we specialize in helping MSBs meet both deferral and state regulatory requirements. For money transmitters, we work hard for our clients to ensure the MSBs’ agents comply, to reduce the likelihood of exposing the MSBs to undue risk of noncompliance.

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