Doesn't criterion 4, "Seller or redeemer of traveler's checks, money orders or stored value", pretty much fit the bill?
Our responses in this thread will be limited until we get some resolution however it is important to understand state law and federal law don't necessarily have the same definitions even for terms with the same "name". Generally speaking the law will define a term and it has that meaning and only that meaning in the scope of that definition.
As we indicated in the response at the federal level however FinCEN has provided guidance that Bitcoins are not stored value and virtual currency does not fall under the definition of "currency dealer or exchanger". FinCEN has changed the definition to "stored value" to be more inclusive of other prepaid products by using the term "prepaid access" however at the federal level "stored value" and "prepaid access" can be considered synonymous.
http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.htmlProviders and Sellers of Prepaid Access
A person's acceptance and/or transmission of convertible virtual currency cannot be characterized as providing or selling prepaid access because prepaid access is limited to real currencies. 18
Dealers in Foreign Exchange
A person must exchange the currency of two or more countries to be considered a dealer in foreign exchange.19 Virtual currency does not meet the criteria to be considered "currency" under the BSA, because it is not legal tender. Therefore, a person who accepts real currency in exchange for virtual currency, or vice versa, is not a dealer in foreign exchange under FinCEN's regulations.
Ok. Fair argument.