That's correct. In the case of Bitcoin, the thing that most closely resembles a "money transmitter" are miners but FinCEN ruled that they are not[0]. A sensible

That's correct. In the case of Bitcoin, the thing that most closely resembles a "money transmitter" are miners but FinCEN ruled that they are not[0]. A sensible decision because otherwise, Bitcoin would have effectively been banned from the United States (or Bitcoin miners, at least). [0] https://www.coindesk.com/policy/2014/01/31/fincen-declares-bitcoin-miners-investors-arent-money-transmitters/ https://www.coindesk.com/policy/2014/01/31/fincen-declares-b...