While 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 delegat

While 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.