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Companies that Facilitate Currency Exchanges are Not Dealers, FinCEN Says

Companies that act only as middlemen between businesses and foreign exchange brokers are neither currency dealers nor money transmitters, and are thus not regulated by the Bank Secrecy Act, the U.S. Treasury Department said Friday. Because such companies do not themselves process a currency exchange and transmit funds only to facilitate a deal between customers and the exchange brokers, they fall outside of the scope of BSA regulation, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) said. The clarification came in one of three FinCEN letters responding to questions from foreign currency exchange companies. U.S. Treasury Secretary Henry Paulson said...

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