Quote from: tytus on March 22, 2013, 07:21:44 PM

Quote from: Stephen Gornick on March 22, 2013, 06:30:04 PM

Or, are all peer nodes now considered "money transmitters" that must register with FinCEN as MSBs.

All nodes that generate blocks (transmitters) must register and (I assume) to be compliant must know both parties of all transactions included in the block. This is impossible and thus the guidelines make Bitcoin illegal [in the US and wherever FinCEN thinks it has jurisdiction :-)]

I would urge the US Bitcoin community to discuss Bitcoin with FinCEN. There are positive statements:
- bitcoin is not a currency
- Users of bitcoin do not need to register.
There is good will from the other party :-)

That wouldn't make any sense. If you look at the complete FinCEN statement they clearly spell out three categories - users, administrators, and exchangers - and the difference between them. I imagine FinCEN had some help understanding the underlying way Bitcoin works, which is why they address it so specifically. If this is true then they would know simply running the software as a full node is a way to be only a user, the one category they say requires no regulation.

I don't think they're looking at the way the underlying network works. I think they're talking about the infrastructure built on top of it.