How are you going to counter VPN's and such?
I have only gave it a brief read through but I thought they had said they were leaving miners/transaction processing alone?
Note though I do not blame you.
Warning to New York Residents
The latest draft of the BitLicense proposal is out, and it is even worse than the last one when it comes to pools. This is an approximately 75-day notice that if you are using the pool from New York, you will need to request your withdrawals and change pools. Once the comment period ends (approx. 30 days) and the BitLicense is approved, unless it is changed, it will leave a 45-day window before it becomes effective. Once the 45-day window begins, the pool will be implementing Geo-IP to ban the creation of accounts from New York, and a splash screen will appear to users who already have accounts telling them that the pool is no longer able to serve them and that they have 45 (or less) days to request their withdrawals. After it becomes effective, the site will no longer be available for access from New York.
Their direct wording is any business involved in the transmission of Bitcoin to a New York resident requires a license. Transmission has no exemptions for mining. Now, if you're *solo mining* in New York, you wouldn't need one, since you're not transmitting to anybody. If BTC Guild used coinbase payouts, it would also be able to bypass this, with one exception: There is no pool doing coinbase payouts (other than p2pool which is not exactly a pool) that doesn't require a failsafe wallet to catch dust/errors, and running a manual fix to distribute the dust/errors later is transmission. Unless BTC Guild turned itself into p2pool by setting a minimum share difficulty high enough that you would always have enough work in the PPLNS system to receive a payout, it's not an option.
Obviously you can't do anything about VPNs, but all accounts will be required to agree to an updated TOS affirming they are not residents of New York, on top of the Geo-IP ban to anybody accessing the site from New York.