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If a business sells gift cards or cashes checks, even as ancillary parts of its business, beware: those activities may trigger its classification as a Federal “money services business” (“MSB”) and state licensing, registration, reporting, recordkeeping and other requirements.  However, if a business satisfies certain criteria, it may be exempt from compliance with such requirements.   This article gives an overview of Federal MSB requirements, but please note that state requirements, which are not described in this article, may also apply.

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Christopher Edwards

Chris Edwards, of Reitler Kailas & Rosenblatt LLC in New York City, provides counsel to a variety of companies, from start-ups to publicly-traded entities, in the fields of venture capital, mergers and acquisitions, banking, securities and general corporate law. He graduated from Harvard Law School in 1998 and previously practiced in the fields of corporate law and structured finance at Cahill Gordon & Reindel, Freshfields Bruckhaus Deringer, Cadwalader Wickersham & Taft and Bank of America. He can be reached at 212-209-3072 or cedwards@reitlerlaw.com.

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