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They're not doing payment proceeding, it's just a wallet.

by qqii 6y ago

davidgerard 6y ago
If 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 ago
  I 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 ago
    Ah, 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 ago
      Quoted 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 ago
        Ok, thanks for clarifying this, I feel like I understand better what's going on now and feel more comfortable with it. Thanks again

They're not doing payment proceeding, it's just a wallet.

by qqii 6y ago

They're not doing payment proceeding, it's just a wallet.

If 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 ago
I 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 ago
  Ah, 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 ago
    Quoted 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 ago
      Ok, thanks for clarifying this, I feel like I understand better what's going on now and feel more comfortable with it. Thanks again