Right. So far, the enforcement framework has it's pivot foot in fiat.  That is,  crypto-to-crypto exchanging and dealing doesn't seem to be the topic of any MSB enforcement at all.  The regs say differently, but laws and the enforcement of those laws are two different things. Government enforcement - at least today at 11am - seems to concern itself only with people operating businesses that deal - at some point in their chain of value - with fiat currency.  Thus, exchanges are prime targets for noncompliance.  That might change 45 minutes from now when FinCEN promulgates a new regulation, or DHS nails a new pure bitcoin business, but for now, dealing in fiat seems to be what makes an MSB a target.

That's only the MSB regulations, though.  What really surprises me is that nobody seems to be talking about the securities laws!  The securities laws are far more byzantine and far-reaching than the MSB regs.  Yet, there are investment pools, informal "stock exchanges" and "stock sales" - none of which comply with state blue sky regulations or the '33 Act.

You heard it here first - the  next big enforcement push his going to be by the SEC.