3 ms·
>or any network of people who engage as a business in facilitating the transfer of money domestically or internationally outside of the conventional financial i
by aspensmonster 13y ago
>or any network of people who engage as a business in facilitating the transfer of money domestically or internationally outside of the conventional financial institutions system
Wouldn't that definition mean that every single bitcoin user is in violation of the act?
- maxerickson 13y ago'engage as a business' means you are probably doing quite a bit of it.
- patio11 13y agoWhile you might think that and I might be inclined to agree with you, that interpretation is at variance with the laws of the United States. FinCEN was delegated rulemaking authority, and their rule is that if you're in check cashing, travelers checks, or what have you, there is a $1,000 a day minimum below which you don't have to be registered, but if you're in funds transfer as a business, you require registration for transferring one red cent. http://www.fincen.gov/financial_institutions/msb/definitions/msb.html http://www.fincen.gov/financial_institutions/msb/definitions... No activity threshold applies to the definition of money transmitter. Thus, a person who engages as a business in the transfer of funds is an MSB as a money transmitter, regardless of the amount of money transmission activity.
- maxerickson 13y agoThe real big risk seems to be that they might not acknowledge that the transfer of bitcoin can happen 'in person'.
- xhrpost 13y agoIANAL, but it appears that if you did all your purchasing and selling within Coinbase (a registered MSB), you would be complying with the law. In the end though, this stuff hasn't been decided in court.
- deleted 13y ago[deleted]