IANAL but according to the quote, it appears illegal to use Bitcoin to buy USD from a third party on behalf of a customer. The point seems to be, they've separated the transaction into two parts (the currency transaction and the sale of the metal) and said "Wait a minute, you're exchanging money on behalf of other people, you need to register". Or am I reading that wrong?

Again, I'm sure this will be no big deal. I am sure existing coin shops and funds will act quickly to rectify their non-compliance. For example, there's over 40,000 licensed money transmitters in the US already, and it only costs $1000 to register in Washington state ([12:32] http://mortgage.nationwidelicensingsystem.org/slr/PublishedStateDocuments/WA-Currency-Exchange-Company-New-App-Checklist.pdf).