In addition to buying and selling foreign currency in its retail branches, _ offers customers the option of buying foreign currency through _’s website and having the currency delivered to the billing address of the customer’s debit or credit card. These branches provide an influx of foreign currency that _ can, in turn, make available for sale to customers and a wholesale network. _ buys and sells select foreign currency at these retail locations. Your client requests a determination by the Department regarding whether its proposed business activity-providing an online foreign currency exchange service-is subject to licensure under the Money Transmission Act (MTA). I have been asked to respond to your request, which you submitted on behalf of your client, _ (_). Thank you for your letter to the Department of Business Oversight (“Department”) dated May 12, 2020, Jconference call, and supplemental emails.
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