In other words, if you run a Bitcoin exchange in the United States and you don't have 47 money transmission licenses, you'd better call your lawyer.
If you own Bitcoins, you should prepare for the very real possibility that one day, depending on arbitrary state or USDOJ enforcement actions, you may never be able to convert your Bitcoins back to dollars.
For a sense of how backwards our financial regulators are, and how poorly they understand the issues at hand, take a look for yourself:
https://www.facecash.com/legal/brown.html#document27
Actual quotes: "We don't regulate technology," and "We don't treat every applicant exactly the same." —Teveia Barnes, Commissioner, California Department of Financial Institutions
(This was last week in Sacramento.)
Everyone should also familiarize themselves with 18 U.S.C § 1960:
http://www.plainsite.org/laws/index.html?id=14426
It's a federal crime to break your state's money transmission law that operates independently of, but is likely to be affected by, FinCEN's federal guidance.
If you own Bitcoins, you should prepare for the very real possibility that one day, depending on arbitrary state or USDOJ enforcement actions, you may never be able to convert your Bitcoins back to dollars.
For a sense of how backwards our financial regulators are, and how poorly they understand the issues at hand, take a look for yourself:
https://www.facecash.com/legal/brown.html#document27
Actual quotes: "We don't regulate technology," and "We don't treat every applicant exactly the same." —Teveia Barnes, Commissioner, California Department of Financial Institutions
(This was last week in Sacramento.)
Everyone should also familiarize themselves with 18 U.S.C § 1960:
http://www.plainsite.org/laws/index.html?id=14426
It's a federal crime to break your state's money transmission law that operates independently of, but is likely to be affected by, FinCEN's federal guidance.