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Taking the service offline was a good move. You can request an administrative ruling from FinCEN. It would be prudent to meet with an attorney first and have t
by will_brown 13y ago
Taking the service offline was a good move. You can request an administrative ruling from FinCEN. It would be prudent to meet with an attorney first and have the attorney draft and send the letter (it may receive a quicker response on attorney letterhead).
As a side note attorneys can not contact you, they can send you advertisements or return your calls but they can not directly contact you, you must contact an attorney. Therefore any attorney who contacts you as a result of this post should immediately raise a red flag in you mind.
In the meantime here is FinCEN's guidance on virtual currencies: http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001....
And FinCEN's final rule on prepaid access(aka gift cards): http://www.fincen.gov/news_room/nr/html/20110726b.html http://www.fincen.gov/news_room/nr/html/20110726b.html
- sumedh 13y ago> As a side note attorneys can not contact you, they can send you advertisements or return your calls but they can not directly contact you, As someone who does not have much idea about laws, why can't an attorney contact him?
- will_brown 13y agoWell the answer as to why is because the Model Rules of Professional Conduct prohibit said conduct. Specifically Rule 7.3, Direct Contact with Prospective Clients, reads as follows: (a) A lawyer shall not by in‑person, live telephone or real-time electronic contact solicit professional employment when a significant motive for the lawyer's doing so is the lawyer's pecuniary gain, unless the person contacted: (1) is a lawyer; or (2) has a family, close personal, or prior professional relationship with the lawyer. Now you may be curious about the justification of the rule...ever hear of the term ambulance chaser? It is a nasty term for attorneys who preyed on prospective clients in very vulnerable states who otherwise would not be able to make a voluntary and informed decision. The rule is meant to protect the public and profession from said behavior.
- sumedh 13y agoThanks specially for the justification.