Quote from: samadamsbeer on May 21, 2017, 02:55:47 AM

George, thanks for this. NH looks like it will explicitly define BTC as not a MSB https://legiscan.com/NH/bill/HB436/2017 once governor signs. Sounds like Nevada is in same boat. For these states, if one were to operate a cash>bitcoin ATM, drawing from a hot wallet (not an exchange), I assume one still needs to register with Fincen. In doing so what is the simplest way to comply with AML/KYC? For example requiring all transactions above a certain $ amount to supply a phone number or ID? Would like it to be simple from the customer and the ATM owner perspective. Does below a certain $ amount require no KYC procedure that the customer must supply?

That's a lot of questions, lol! There are answers to all of them that have been researched and labored over Yes, you would still need to register with FinCEN and make a good faith effort to comply with AML and KYC. As to the other information, well, I paid dearly to get it so I charge to share it. You are welcome to contact me via PM. BTW, I'm not convinced that exchanging cash for BTC and the reverse is not acting as a money transmitter. Yes, there are some educated guesses that have to be made as the regulator's are not sure either. However there are steps that can be taken preemptively to give you some cover, at least for awhile.

Best:

George D. Greenberg, Esq.
www.attorneybitcoin.com