Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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7/21/2005 Definition of Money Services Business Refined by FinCEN Rulings

A gaming establishment with gross annual gaming revenue of $1 million or less does not trip the threshold of 31 CFR 103.11(n)(5) for being a "casino," yet it may be a money services business if it conducts activities putting it in that category. If the gaming revenue exceeds $1 million, it is not an MSB but comes under the casino regime, according to FinCEN Ruling 2005-5. A bank need not treat a supermarket chain as an MSB if the chain has ceased to conduct activities, such as check cashing services, that would make it an MSB.  This, according to FinCEN Ruling 2005-3, is true even if the supermarket chain's registration as an MSB has not expired. These and other recent rulings refining the specifications of what constitutes an MSB will be discussed in the September issue of the Monitor. 

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