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The FinCEN guidance explicitly states that Currency Exchange regulations do not apply: http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html http://
by julespitt 13y ago
The FinCEN guidance explicitly states that Currency Exchange regulations do not apply:
http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001....
"A person must exchange the currency of two or more countries to be considered a dealer in foreign exchange. Virtual currency does not meet the criteria to be considered 'currency' under the BSA, because it is not legal tender. Therefore, a person who accepts real currency in exchange for virtual currency, or vice versa, is not a dealer in foreign exchange under FinCEN’s regulations."
Edit: Just need to clarify that Money Transmitter regs do apply.
- apaprocki 13y agoRegulations certainly apply. For example, in the case of Bitfloor's local BoA deposit, a third party was accepting cash deposits and forwarding the money to the exchange. That requires the third party to be a money transmitter and could have repercussions if the bank account was also with BoA.
- julespitt 13y agoSure - I was just responding to the claim that it was Currency Exchange regulations that apply here.