There are several things going on here it seems. I'll see how many I can address.
1. Federal Money Transmitter License - There is actually no such thing at a federal level. The only thing the Fed's require is that you register and file SAR reports when deemed necessary. They also want us to check to ensure we aren't doing business with anybody on the OFAC list. We are registered and the list checking and reporting is fairly easy to do, but detecting suspicious activity is a very subjective thing. It's certainly easier to determine suspicious activity when dealing with USD. Before launching USD, we will have the necessary items in place.
2. State Level Licenses - The states aren't going to come and shut you down, but they may fine you and tell you not to deal with people in their state until you get licensed there. We are in the process of getting state licenses. Some are harder than others. This is another thing we are waiting on before doing USD. Many of the states who we previously thought would require a license have stated that we probably do not need one. Many states have laws which were written before the internet. Some state requirements are a little overboard.
3. SR stuff. Just because some coins passed through a service that ended up at SR doesn't mean that it would be covered under any laws which would result in forfeitures. Only if we were willfully and knowingly performing such actions, which we are not. We may be subpoenaed for information in such cases where funds pass through here, which of course we would comply with.
BigVern