That's not the Code it's 'guidance', the law is pretty simple all money transmitters (which WU is) must be licensed, so the legal question/argument is, does having an agents license of the worlds #1 Money Transmitter cover you?

Facts

48 States have money transmitter rules and if you are a WU agent, you should be compliant, since they hold the master license which WU then fraction into agent agreements.

So as an 'agent' of WU you are a defacto licensed money transmitter under their agent license which is pretty much global in nature.

Now the definition of 'currency' or things of 'value' are in the new fed definition of money transmitters, so any licensed money transmitters and their agents are covered. If a business then gets a 2nd money transmitter license, why would they when their agency agreement complies?

I'm not offering 'legal advice', I'm welcoming legal discourse on IF a WU license can be viewed as compliance.

IMO it does comply, since as an agent you have to agree to the general terms of service of WU which is compliant with money laundering rules and various transaction record keeping rules.

FACT

A WU agent is under the umbrella money transmitter global licenses of WU as a LICENSED MONEY TRANSMITTER AGENT of WU, so that license is not just for US Currency it applies to global currencies and right now the CRS report to congress is saying Bitcoin is a new global currency, it's not traditional fiat currency but it is a new type of currency, so the argument is any currency is exchangeable via WU transfers, a person wherever can transfer to a WU whatever currency they want to be received by the agent who then converts into the currency the receiver wants, so when the 'WU agent' is the company/person/business receiving or sending whatever, they are doing it under a WU license to transmit 'money' and virtual currency is now technically considered 'money' or something of value, so that's why a money transmitter license is needed and when a business wherever obtains an agent right with WU then WU has the license to allow 'money' transmission.

I don't see anything in the actual code stating a business would need to double license a business just to take a virtual currency since all things of value is the new definition so WU agents are licensed agents under the WU master money transmitter license in whatever jurisdiction WU operates in which is pretty much most of the world.

Now if the new codes say you can't use an established money transmitter license to do virtual currency, then a double license would be needed. For example when a business takes WU they need to usually show some type of ID to receive it to the agent, granted minor amounts in some jurisdictions can do so-called password only receipt and no ID, but WU has in place already operational rules that severely limit such transactions.

So from the discussions I've had with lawyers and even judges on this issue is, bitcoin is currency and you need a money transmitter license, so the issue is now does a WU agent license establish compliance? Unless the code says WU is not for virtual currency, you need a different license, then ok, but the rules are saying you need to get a money transmitter license in your area at least and a WU agent license is a money transmitter license, so it should be compliance.

A judge would look at the CODE not the guidance, since precedent is how judges view laws/codes, any cases where WU is considered to not be a money transmitter license? No, so WU and its agents by precedence is a defacto 'money transmitter' so all agents are defacto money transmitters until a judge rules they are not, then that ruling is precedence in that courts jurisdiction. Since district federal courts often come to different conclusions of LAW based upon COURT PRECENDENTS and not some bs guidance opinion, the LAW or JUDGES will eventually be deciding what THE LAW/CODE means, and the code is clear, money transmitter license is required and agents of WU have a valid money transmitter license as a legal agent of WU.

So if you are say in the 3rd Federal District region such as FL and GA, you get involved in a legal proceeding, the judge looks at the LAW/CODE and says ok this business has a duty to be a LICENSED MONEY TRANSMITTER where's your license, they say ask WU I'm an AGENT of their money transmitter license, the judge can look at previous case law and make a ruling, if the judge does what they call bench legislation, where he/she decides a WU agent is not a money transmitter, then the whole WU concept is destroyed.

Or the judge can rule, well the law involves currency and bitcoin is not currency, yet by definition of LAW/CODE anything of value is not subject to money transmitter license so it is technically now currency, just not traditional currency that a government regulates, but the act of having a right to transmit 'currency' by WU does in some legal opinions of lawyers and judges I've spoken to seem to comply.

So a money transmitter license is a right to transmit things of value now as defined by the code/law so an agents right under a master money transmitter license which at this point WU may in fact be a legal right to transmit all currencies or things of value as money is now defined in the CODE/LAW.

So an agents defense is look court I'm an agent of WU and that is the licensed money transmitter license involved so I am compliant.

If a court/judge says no, then that's precedence in their district and they have 13 districts of federal courts and a more sub districts and special districts as well.

So a money transmitter license whether in the name of the business or in the name of the master license holder in this case WU should be in the eyes of the courts/judges a legal right to do any type of 'money' transmission.

The point is in the USA the Feds want businesses LICENSED and WU and its agents are LICENSED MONEY TRANSMITTERS.

The fact is the Feds have put all things of value now as 'money' or currency in the new definition so a WU license is compliance now in the eyes of some lawyers and judges.

Are you a lawyer?

Have you discussed with a lawyer or a judge if a WU agent is not allowed to do transactions that as a side part of the transaction involve bitcoin?

I don't see a new fed law for money transmitters they are using the one already in place and just expanding what they define as money or a thing of value, so by LAW/CODE bitcoin is now something licensed money transmitters already licensed can use to convert whatever came across the wire.

If someone wants bitcoin they can wire you WU money, instead of giving that person traditional currency you just give them bitcoin, something of value and that's why money transmitter licenses are required and as such WU agents should be able to exchange what they receive for anything of value that is legal.