This is dumb as hell. The FinCEN rules talk about this as "value that substitutes for currency", which this is absolutely doing. If you use phone cards as a mon

This is dumb as hell. The FinCEN rules talk about this as "value that substitutes for currency", which this is absolutely doing. If you use phone cards as a money substitute, it's money transmission. If you use bottles of Tide detergent as a money substitute, it's money transmission.