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Can a money transfer agent location be opened in a consulate or an embassy?

The answer is no. When we look at making a consulate or an embassy, as a money-transfer agent location, you have to understand that the consulate or the embassy itself is not US Territory (assuming this question was being asked of the US) in fact this can be applied to any other licensed jurisdiction.

With the regulator, you would have to define an address as an agent location, but a consulate address or an embassy address would not be valid, as these are considered not part of the country they are in, but rather the territory of the country whose flag they are under. 

So, in this case, when you define a consulate as a territory, you’re basically saying you’re opening an agent location internationally and that’s not allowed.

Well, it’s something that a lot of people have thought about you know, there are, there are a lot of consulates in California, Texas, Florida, basically the southern belt of the United States. 

One problem is the enforcement. If you are seeking to build a consulate as an agent location you can’t because they (law enforcement authorities and the regulators) do not have the right to come into your consulate or embassy for an audit or whatever. They simply do not have the right. The federal and state laws do not apply there.

This page was last updated on October 18, 2021.

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