"..if you run a Bitcoin exchange in the United States..." It doesn't just apply to the United States. See http://www.fincen.gov/statutes_regs/guidance/html/FIN

"..if you run a Bitcoin exchange in the United States..." It doesn't just apply to the United States. See http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-A001.html http://www.fincen.gov/statutes_regs/guidance/html/FIN-2012-A... for info on how entities located outside the US will qualify as MSBs (and be subject to the registration and reporting requirements of the Bank Secrecy Act) if they "offer MSB services in the United States from foreign locations." None of this is at all surprising and won't have come as a surprise to anyone with an ounce of common sense. The same principle of extra-territoriality has been applied to foreign banks that deal in USD or accept deposits from US citizens, and to online gambling sites that accept payments from people located in the US.