Section 4 deals with reporting requirements for services.
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A reporting entity must carry out a procedure to verify a customer's identity before providing a designated service to the customer. However, in special cases, the procedure may be carried out after the provision of the designated service.
Section 6 defines the services.
Section 5 defines the various words.
The definitions of "Person" and "Money" are bulletproof. However, within designated services, there is a turn of wording I believe may have been written to invalidate applicability to accounts comprised solely of virtual currency (and with a sympathetic judge, could well exclude any form of money, great job Parliament!)
However further down Section 6 it also provides for depository services other than accounts.
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accepting money on deposit (otherwise than by way of deposit to an account), where the deposit-taker is:
Allowing customers' bitcoins to be stored in a server-owned wallet is a no-brainer for 'deposit' (which, by the way, isn't defined in the law.) However, simply storing a wallet.dat for a customer, basically acting as a file host since that wallet will be directly accessible and downloadable, and since it's the blockchain that manages it, arguing that the wallet.dat is a "deposit" is tenuous at best.
I've tried to find relevant court cases and decisions, but I haven't found any that address the depository issue, so if it does end up in court it'll be a landmark.
