FinCEN Grade D

License requires

1. MSBs (Money Services Business) must register with the Department of the Treasury and renew their registration every two years.
2. Agents of MSBs are not now required to register regardless of the dollar volume of their money service activities (in a change from the proposed rule) unless they engage in money service activities both on their own behalf and as an agent for others.
3. MSBs must maintain a list of their agents and update the list annually.
4. The initial registration form must be filed by December 31, 2001, and the initial agent list must be prepared by January 1, 2002.
5. The term "money services business" does not include a bank or a person registered with and regulated or examined by the Securities and Exchange Commission or the Commodity Futures Trading Commission.
6. The definition of money transmitter clarifies that the activity that makes a person a money transmitter must be carried on as a business, and that generally the acceptance and transmission of funds as an integral part of the execution and settlement of a transaction other than the funds transmission itself (e.g., in connection with a bona fide sale of securities), will not cause a person to be a money transmitter.
7. Issuers and sellers of stored value are included as MSBs, but they are not required to register at this time.
8. Treasury also is announcing its intention that suspicious activity reporting requirements for money transmitting and the traveler’s checks and money order segments of the industry will be forthcoming. In the coming months, Treasury and FinCEN will be working with the industry to develop guidance to assist in identifying suspicious activity.
9. To permit effective implementation, Treasury will not begin requiring suspicious transaction reporting until the registration process is complete.