The Financial Crimes Enforcement Network is issuing this interpretive guidance to clarify whether a non-bank owner and operator of an automated teller machine (ATM) would be a money services business (MSB) as that term is defined under the Bank Secrecy Act and its implementing regulations. Specifically, this guidance addresses whether a non-bank owner-operator of an ATM that offers the limited range of services described below would be deemed a currency dealer or exchanger or a money transmitter, and therefore would be an MSB.
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