Hello all,

During a review process, we discovered that one of our foreign corporation clients is offering purchase and sale of foreign currency, including currency transfers. This client, however, does not have a physical presence in the U.S. - They only maintain accounts with us. In terms of the FinCEN MSB Final ruling on foreign MSBs, does this rule apply to our client? Meaning, does the business require to be registered with FinCEN?

Anyone? Please?

AquaMarine, here is a link to the Federal Register that will answer your question in detail:

http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-A001.html

Also, here is the link for the MSB home page of FinCEN:

http://www.fincen.gov/financial_institutions/msb/advisory.html

AquaMarine,

Please give people a little time to respond before you "bump," a post: 24 hours minimum. Most of the people who answer questions here are supposed to be at work...