In United States v. Uddin, a United State District Judge in Detroit held that a person may be prosecuted for operating an illegal money transmitting business under 18 U.S.C. 1960 where the government shows that the person operated a money transmitting business that he knew was not registered with FinCEN. The judge rejected the defense argument that the government also must show that the person operating the money transmitting business knew that the business had to be registered, thereby following the general rule that ignorance of the law is no defense. This case illustrates that money services businesses are responsible for knowing their registration obligations under the Bank Secrecy Act and implementing rules.

Opinion
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