Post
Topic
Board Project Development
Re: Bitcoin Lawyer Introduction Thread
by
xf2_org
on 10/06/2011, 19:51:50 UTC
To meet the definition of an MSB, a person must conduct more than $1,000 in business with one person in one or more transactions (in one category of activity listed above) on any one day. A business is an MSB for each activity for which it meets this threshold. However, there is one exception. No activity threshold applies to the definition of money transmitter. A person that engages as a business in the transfer of funds is a money transmitter and an MSB, regardless of the amount of transfer activity.  (see http://www.fincen.gov/financial_institutions/msb/pdf/FinCENfactsheet.pdf )

Since bitcoins are "stored value" and not directly money, there is a FinCEN ruling that is relevant:
http://www.fincen.gov/statutes_regs/guidance/html/fin-2009-r001.html