Please report every single shop that sells gold or other precious metals and has a facility to post them to customers. And every shop that allows you to send them gold in exchange for cash.
Seriously. They are all money transmitters and if not regulated, they are breaking the law. File an online report to FinCen, its your duty to help protect the US of A.
Is this really the case? Wasn't gold demonetized in the US? The Bernank calls it an "asset".
If your idea is to break the system through over-compliance, that would not result in anything better than the way things are.
More reasonable is Mike's method of doing the perfunctory compliance requested, and then challenging the justification for it.
He's not a money transmitter if you are selling to purchasers.
Money transmitters send money to those other than from whom they received them, and there isn't any evidence that Mike is doing that.
FinCEN is concerned that with the volume of money, there might be some folks making use of Mike's good will efforts to engage in their own money transfers by buying things for others without Mike knowing and probably think he should be making sure the folks paying for something are the folks receiving it, which takes a bit of KYC.
Alternatively if he sent the stuff signature-required, that would also probably cover himself too. FinCEN is really barking up the wrong tree here. Mike's simply a merchant selling a product.