FinCEN's guidance on crypto business models: are you a money transmitter?(davidgerard.co.uk)

3 pointsby davidgerard7 anni fa1 comments

davidgerard.co.uk

FinCEN's guidance on crypto business models: are you a money transmitter?

https://davidgerard.co.uk/blockchain/2019/05/09/fincens-guidance-on-crypto-business-models-are-you-a-money-transmitter/

1 comments

I am hardly a fan of Gerard but this is a well written summary of the guidance.

The only thing I would add to clarify money transmission as "transmitting value that substitutes for currency" is that exchanging funds for goods (normal commerce e.g. buying a coffee with credit card / cash / apple pay / stablecoin) is probably not considered money transmission. But I'm not your lawyer.