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Not to excuse signal but has the response really been justified for a beta feature being tested in a single country? The signal press release and activity on th
by qqii 6y ago
Not to excuse signal but has the response really been justified for a beta feature being tested in a single country? The signal press release and activity on the forums makes it clear that they're asking for feedback.
Their intentions were never hidden either, you can see interviews dating 2017 thst matches their current stance.
- TheSpiceIsLife 6y agoThey’re asking for feedback? Then the response is justified. If you’re doing payment processing then you need to abide by AML and KYC laws, which are incompatible with secure messaging.
- qqii 6y agoThey're not doing payment proceeding, it's just a wallet.
- davidgerard 6y agoIf money moves over the network, it's payment processing. I urge you to review FinCEN guidance on "convertible virtual currencies". https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20... Similar regulations apply in most of the developed world. FATF regulations on virtual currencies only get tighter.
- 3np 5y agoI did review this and my understanding is that for “self-hosted” wallet apps like this where the keys are on users devices and there is no custody, Signal is clearly not classified as a VASP/payment processor. Care to point to the contradictory section? Because that would be drastic and contrary to anything I’ve heard.
- TheSpiceIsLife 5y agoAh, yeah right, looks like I've got my terminology and assumptions confused. That PDF linked above ( https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20CVC%20Guidance%20FINAL.pdf https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20... ) would indicate Signal would be a 'money transmitter' rather than 'payment processor'. Is that correct, or am I still confused.
- 3np 5y agoQuoted from above PDF 1.2.1: > FinCEN’s regulations define the term “money transmitter” to include a “person that provides money transmission services,” or “any other person engaged in the transfer of funds.” A “transmittor,” on the other hand, is “[t]he sender of the first transmittal order in a transmittal of funds. The term transmittor includes an originator, except where the transmittor’s financial institution is a financial institution or foreign financial agency other than a bank or foreign bank.” As long as Signal or its servers don't itself take part in transmission (which they wouldn't as long as the Signal app acts as a real user-side wallet and client) or trades/converts assets on behalf of the users, they should be exempt of this regulation. Say what you want about this regulation, but so far I find it reasonable; as long as you as a business don't touch crypto assets or private keys either as issuer, key custodian, or transmitter but simply provide the wallet/node software, you're in the clear. Unless Signal acts in bad faith, I see no way they would fall under scope of Fincen regulation wrt MobileCoin. IANAL etc.
- TheSpiceIsLife 5y agoOk, thanks for clarifying this, I feel like I understand better what's going on now and feel more comfortable with it. Thanks again
- 3np 5y agoIs Signal doing payment processing here? Like issuing or selling MobileCoin? If it’s just a non-custodial wallet then they’d be in the clear.