Here is the situation:
I'm a small business. I am in business of buying Bitcoins.
Please note, I'm not trading or selling them - just buying.
Customer sends me Bitcoins, I send the USD-denominated bank wire.
Questions:
Do I need to register my business as Money Transmitter?
If yes, how do I do this?
Additional info:
Please see FinCEN Guidance on virtual currencies:
http://www.fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html
Especially:
Side question:
Are there any limitations or exemptions [that will permit me NOT to register as Money Transmitter] to above definitions?
I'm a small business. I am in business of buying Bitcoins.
Please note, I'm not trading or selling them - just buying.
Customer sends me Bitcoins, I send the USD-denominated bank wire.
Questions:
Do I need to register my business as Money Transmitter?
If yes, how do I do this?
Additional info:
Please see FinCEN Guidance on virtual currencies:
http://www.fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html
Especially:
Quote
Under FinCEN’s regulations, sending “value that substitutes for currency” to another person or to another location constitutes money transmission
Quote
An administrator or exchanger that (1) accepts and transmits a convertible virtual currency or (2) buys or sells convertible virtual currency for any reason is a money transmitter under FinCEN’s regulations
Side question:
Are there any limitations or exemptions [that will permit me NOT to register as Money Transmitter] to above definitions?
You should consult your accountant first - according to the money movements of your company bank account - if they can manage the paperwork on buying crypto currency - thats not money transmission yet. It's like if you change your money to Euros or Yens - as soon as the goverment accept crypto as a currency - I'd ask my accountant first.
