Financial Crimes Enforcement Network Guidance: Application of the Definition of Money Transmitter to Brokers and Dealers in Currency and Other Commodities, September 10, 2008 [open pdf - 54KB]
"The Financial Crimes Enforcement Network ('FinCEN') is issuing this interpretive guidance to clarify whether a person who conducts transactions in currency or other commodities is a money services business for purposes of complying with the Bank Secrecy Act and its implementing regulations. Specifically, this guidance addresses whether a broker or dealer in currency or other commodities is a money transmitter when, in the ordinary course of business, the broker or dealer accepts and transmits funds in order to effect transactions in currency or other commodities for or with a customer."
FinCEN Guidance FIN-2008-G008
Financial Crimes Enforcement Network: http://www.fincen.gov