Gift cards are not an exchange of currency.
Gift Cards = Stored Value Cards and therefore are regulated by FinCEN
"(3) Issuer of traveler's checks, money orders, or
stored value. An issuer of traveler's checks, money orders, or, stored value (other than a person who does not issue such checks or money orders or stored value in an amount greater than $1,000 in currency or monetary or other instruments
to any person on any day in one or more transactions). "
That puts them under FinCEN, but classified as a Money Exchanger ?
Money Services Business - The term "money services business" includes any person doing business, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities:
(1) Currency dealer or exchanger.
(2) Check casher.
(3) Issuer of traveler's checks, money orders or stored value.
(4) Seller or redeemer of traveler's checks, money orders or stored value.
(5) Money transmitter.
(6) U.S. Postal Service.
As I read that, bitcoin falls under 1 and not 3/4
So it is still under MSB regulations but not all those defiinitions are necessarily the same rules, as one would expect there are different regulations for a Check casher than the U.S. Postal Service.
Bitcoin does not fall under 1 it falls under 5. 1 is out because it uses the language "currency of a foreign government". 5 is FinCEN way of forcing Bitcoin (round peg) into a MT definition (square hole). It is the only thing which even comes close so FinCEN has used that.