Iraqi dinar sales. While it is not necessarily illegal to buy or sell Iraqi currency
Suspicious Activity Involving the Iraqi Dinar
Over the last year, the circumstances of the war in Iraq have created the phenomenon of businesses trading in new Iraqi dinars. Many of these businesses advertise or conduct business over the Internet, and suggest that the Iraqi dinar, much like the Kuwaiti dinar following Operation Desert Storm, will increase in value exponentially following United States military involvement in Iraq. Most investors purchase dinars from websites established particularly for selling dinars or from major auction websites.
FinCEN has been receiving inquiries regarding the legitimacy of websites offering Iraqi dinar sales. While it is not necessarily illegal to buy or sell Iraqi currency, there are a number of risks and compliance concerns for the financial community. For example, Iraqi officials state that it is illegal under Iraqi law to export dinars. Therefore, in addition to questions about the source of the currency, and the potential for investment or securities fraud, businesses offering to sell dinars may also pose the risk of being used to fund terrorism or as a vehicle for money laundering.
FinCEN also has a particular interest in these businesses because they may be money services businesses required to comply with the Bank Secrecy Act.
Any United States entity that buys or sells currency, including Iraqi dinars, in amounts of more than $1,000 U.S. to any one person in one day may be a money services business under FinCEN’s regulations at 31 C.F.R. Section 103.11(uu). [Note: there have been questions about the old dinar with Hussein’s picture on it. That dinar ceased to be legal tender around January 15, 2004 and thus ceased to be currency for purposes of the Bank Secrecy Act.] Money services businesses include: • Money transmitters; • Currency Dealers or Exchangers (except those who do not exchange more than $1,000 in currency or monetary or other instruments for any person on any day in one or more transactions); • Check cashers (except those who do not cash checks in an amount greater than $1,000 in currency or monetary or other instruments for any person on any day in one or more transactions); • Issuers, sellers, or redeemers of traveler’s checks, money orders, or stored value (except those who do not issue, sell or redeem such instruments in an amount greater than $1,000 in currency or monetary for or from any person on any day in one or more transactions)
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