>Currency dealer or exchanger
So the US federal government has determined that Bitcoin is a currency? That would be pretty big and AMAZING news. The price is what $20,000 USD per BTC by now right.
You have court cases, cites, regulatory memorandums, administrative rulings ... ... ...
There are other regulations which apply to "value transfer" and "stored value". That's why you can't just look at one bit of the regulations in isolation and claim that nothing can be applied to Bitcoin. How you're actually
using something often determines what laws apply. Even with USD, which regulations apply depend on how they're being used.
It's easy to say "they can't apply regulation X because Bitcoin isn't Y", but it's not your ass which is on the line if you're wrong about that or you who'll have to appear in court and find the funds to challenge any ruling where they
do try to apply regulation X.
Hopefully we can one day buy and sell bitcoin p2p easily and the regulators can go fuck themselves.
People seem curiously reluctant to do that, though - possibly because at this point more users are interested in Bitcoin as a means of making a quick profit than are interested in using it as a P2P payment protocol.