Just to clarify - let's say someone wants to setup a cash>BTC ATM machine. Ignoring the state requirements for a moment - what constitutes compliance at the Federal level? I see many of these machines simply asking for a. fingerprints b. IDs or c. cellphone numbers alone to enable transactions. Would these methods suffice to KYC at the federal level? I know the states can make things vastly more complex but again, ignoring the states for a moment.
I believe you are correct. The ATMs I have visited in the U.S. require some "proof" of identity by scanning an ID and/or the other things you mentioned. The business just has to demonstrate that it is trying to keep out money laundering, and that they have tried to determine the identity of the user. The reason the government can insist is because the transaction involves their money. Remember, you CAN NOT own dollars. 
Topic: Is there any place I can find FinCEN AML/KYC requirements for a BTC trader? (Read 1531 times)
May 23, 2017, 08:58:58 AM
May 20, 2017, 09:43:39 PM
Just to clarify - let's say someone wants to setup a cash>BTC ATM machine. Ignoring the state requirements for a moment - what constitutes compliance at the Federal level? I see many of these machines simply asking for a. fingerprints b. IDs or c. cellphone numbers alone to enable transactions. Would these methods suffice to KYC at the federal level? I know the states can make things vastly more complex but again, ignoring the states for a moment.
April 26, 2017, 08:07:00 PM
You are not going to like this answer. 
I think you will need to first register as a MSB: https://www.fincen.gov/money-services-business-msb-registration
To transfer funds you will likely need to get a "Money transmitter" license in each state you will operate. I have read that in some states it could be as high as $25 million dollars.
A selection of AML forms and rules can be found here: http://www.finra.org/industry/aml
This page does a reasonable job of explaining the KYC requirements: http://www.exim.gov/policies/due-diligence-standards
I think you will need to first register as a MSB: https://www.fincen.gov/money-services-business-msb-registration
To transfer funds you will likely need to get a "Money transmitter" license in each state you will operate. I have read that in some states it could be as high as $25 million dollars.
A selection of AML forms and rules can be found here: http://www.finra.org/industry/aml
This page does a reasonable job of explaining the KYC requirements: http://www.exim.gov/policies/due-diligence-standards
He's right. It's a nightmare of paperwork and time, and unless you have very deep pockets, live in very specific States, or will have a funding round for your business, it's really, really expensive.
It will take months, you will need to hire a compliance officer and have a clearly stated procedure (for betting customers and reporting anomalies/suspicious activity).
Might want to consider setting up that exchange abroad
April 26, 2017, 02:30:08 PM
You are not going to like this answer.
I think you will need to first register as a MSB: https://www.fincen.gov/money-services-business-msb-registration
To transfer funds you will likely need to get a "Money transmitter" license in each state you will operate. I have read that in some states it could be as high as $25 million dollars.
A selection of AML forms and rules can be found here: http://www.finra.org/industry/aml
This page does a reasonable job of explaining the KYC requirements: http://www.exim.gov/policies/due-diligence-standards
I think you will need to first register as a MSB: https://www.fincen.gov/money-services-business-msb-registration
To transfer funds you will likely need to get a "Money transmitter" license in each state you will operate. I have read that in some states it could be as high as $25 million dollars.
A selection of AML forms and rules can be found here: http://www.finra.org/industry/aml
This page does a reasonable job of explaining the KYC requirements: http://www.exim.gov/policies/due-diligence-standards
April 09, 2017, 04:05:38 AM
I want to become a local bitcoin exchanger since I know many bitcoin buyers/sellers, and I already understand all the requirements for my state, but I seem to be unable to find any clearly described reporting requirements for the federal level. Specifically I am talking about the KYC/AML reporting and documentation requirements. I believe I've read most of the posts on this forum about this topic, and haven't found anything tangible that is helpful to someone looking to become a bitcoin trader / money transmitter.
Can anyone point me to some resources? All of the information I can find online only talks about registering with FinCEN, and then vaguely mentions that there is KYC/AML requirements, without going into any detail.
Can anyone point me to some resources? All of the information I can find online only talks about registering with FinCEN, and then vaguely mentions that there is KYC/AML requirements, without going into any detail.
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