Unfortunately you understood correctly….
Not only US citizens but also US residents…
According to the US law, even though we are a foreign company holding a US$ bank account with a European Bank, we are subject to US money transmitting laws like any other US based company.
Therefore, we should apply for FINCEN registration which is not difficult but, also, we will have to apply for all State licenses which, as you may know by now, it is not an easy issue….
Hopefully, in the future, we will be able to revise this policy but, for the time being, we prefer to be safe than sorry….