Do you deal in or exchange currency for your customers
Does your business accept funds from customers and send funds on customers instructions
the main questionis.... did MTGOX or Dwolla customer's ever send to or receive funds DIRECTLY from the Mutim sigilum bank account(76XXXXXX13)
the requirement of a money transmission licence all depends on how the mutim sigilum LLC account was used.
if CUSTOMERS put money in or received money from the Mutim sigilum bank account(76XXXXXX13) held with the american bank Wells fargo then YES mutim siligum was involved with money transmission on behalf of customers.
paypal analogy:
if customers were given your bank account number to be used to then credit your paypal account and you repaid customers by withdrawing from paypal to then bank transfer back to customers using your BANK then yes your BANK account would need a money transmission licence.
the flip side.
if customer only funded Dwolla's own bank account with just reference numbers to ensure it reached mtgox's dwolla member ID (81x-xxx-xx10) then NO mutim siligum was not involved with money transmission on behalf of customers.
this is because as soon as it hits the Dwolla member id for mtgox, it becomes MTGOX's property and they can move their own funds through their own subsidiaries freely.
paypal analogy. someone puts money into your paypal account. you withdraw it to your actual bank account. you also deposit from your bank account back in to paypal. as soon as it hits paypal it still remains your property until you hand it to the customer.
so your BANK account is not touching customers money, just your profit/income/outgoing.
