3 ms·

> operating an unlicensed money-transmitting business. Can you be a money-transmitting business if you never have access to any of the funds being transmitted?

• skywhopper 3y ago
  Yes.
  • bordercases 3y ago
    What non-circularly defines a money-transmitting business?
    • nradov 3y ago
      Here is the legal definition of a money transmitting business. https://www.law.cornell.edu/uscode/text/31/5330#d_1 https://www.law.cornell.edu/uscode/text/31/5330#d_1
      • tromp 3y ago
        Part A: > provides check cashing, currency exchange, or money transmitting or remittance services says that Samourai is a money transmitting business iff they provide a money transmitting service. Part B: > accepting currency, funds, or value that substitutes for currency and transmitting the currency, funds, or value that substitutes for currency by any means says that they must be accepting currency/funds/value, which they don't appear to be. They only accept instructions from each user for how to spend funds to themselves.
        • JumpCrisscross 3y ago
          > provides check cashing, currency exchange, or money transmitting or remittance services They're exchanging currency. (SWIFT is just a messaging service, for example.)
          • cryptonector 3y ago
            That's right, a crypto mixer that affords true privacy (except relative to the mixer itself) w/o additional controls (e.g., transaction limits comparable to practical limits on cash transactions) is definitely a money laundering enabling capability. Whether one can conclude that the people running the crypto mixer are engaging in criminal activity will depend on the text of the relevant statutes, though I'm pretty sure those will be fairly airtight.
• deleted 3y ago
  [deleted]