Faisal KhanAnswered Jun 1, 2012The FinCEN documentation on who is an MSB is here: http://www.fincen.gov/financial_... - The exceptions are clearly noted on that page, also see the definition of an Agent (which is also an exception): http://www.fincen.gov/financial_...
A person who makes MSB/FinCen licensing his life is a lawyer called Adam Atlas (See: http://www.adamatlas.com/). You may want to read up on his blog as well (very helpful): http://moneytransmitterlicense.b....
To answer your question in show, Not-For-Profits still need to register. The 5 times or less I have not read about, but the threshold value in US$ term has clearly been identified in the link above, below which you are not required to register with FinCEN.
A person who makes MSB/FinCen licensing his life is a lawyer called Adam Atlas (See: http://www.adamatlas.com/). You may want to read up on his blog as well (very helpful): http://moneytransmitterlicense.b....
To answer your question in show, Not-For-Profits still need to register. The 5 times or less I have not read about, but the threshold value in US$ term has clearly been identified in the link above, below which you are not required to register with FinCEN.