c. Bitcoin
A final type of convertible virtual currency activity involves bitcion, a virtual currency (1) that has no central repository and no single administrator, and (2) that persons may mine.
A miner that uses bitcoin to purchase real or virtual goods and services is a user of the convertible virtual currency and not subject to regulation as a money transmitter. By contrast, a miner that sells bitcoins to another person for fiat is engaged in transmission to another location and is a money transmitter. In addition, a person is an exchanger and a money transmitter if the person accepts bitcoin from one person and transmits it to another person as part of the acceptance and transfer of fiat.
This practically effects:
1) Exchanges, but they already knew that.
2) Middlemen that convert bitcoin to USD, like BitPay.
3) Mining pools that directly allow you to cash out in USD.
Now here's a thought...
According to the way I read this:
"In addition, a person is an exchanger and a money transmitter if the person accepts such de-centralized convertible virtual currency from one person and transmits it to another person as part of the acceptance and transfer of currency, funds, or other value that substitutes for currency."
...the bitcoin mixers and laundry sites are not on the hook as money launderers. Does it look like that to you?