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Interpretive Release: more than guidance, it’s “binding”

No money service business should be lulled into believing that FinCEN's first-ever Interpretive Release, on "Anti-Money Laundering Program Requirements for MSBs with respect to Foreign Agents or Counterparties," is an innocuous piece of guidance. According to William Langford, associate director of the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) and head of the agency's newly established Office of Compliance, the "Interpretive Release" is "binding" and has the force of regulation. More than just guidance, the interpretive release allows FinCEN to show regulated institutions how "the agency is interpreting its own regulation," Langford said in an interview with Moneylaundering.com Premium...

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