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Now the miners and mining pool will be considered as money transmitters and also bitcoin payment processors have to know the identity of the person making the purchase at merchant's site.
Now the miners and mining pool will be considered as money transmitters and also bitcoin payment processors have to know the identity of the person making the purchase at merchant's site.
You're drawing conclusions that FinCEN specifically said not to draw. They stated, several times, that these rulings are specific to the exact business models described by the companies in the documents presented to them, and the rulings are NOT intended as any new precedent or more broad communication, interpretation, or guidance.
The first ruling is basically irrelevant; an exchange is ruled to be engaging in currency exchange, and is therefore a money transmitter. That's been a "duh" since the March 2013 guidance.
The 2nd ruling is the interesting one. This one rules on a sort-of reverse-BitPay type model, declaring that the company is not eligible for either or two possible "payment-processor" exceptions to the usual money transmitter rules.
In any event, until the exact business model of an existing bitcoin payment processor (or mining pool) gets ruled on, or until new general guidance is issued, the federal regulatory landscape that these businesses are under remains unchanged since March 2013.
