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Won't scale. I explained why if you had clicked my quote to read the rest of my post.
There can be many central ledger providers so this is not an issue. Once one makes it easy to fund and return funds it is easy for there to be many different providers who could specialize in publishers in different jurisdictions. This means that an aggregator can choose to only deal with a limited number of jurisdictions. We must keep in mind that Google has been doing this with adsense advertising for well over a decade. The typical market value of a page view with decent content is well under 0.01 USD. Facebook by the way does far worse than the market average under 0.001 USD per page view.
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The merchants receiving the payouts do fall under AML/KYC. And any MSB has to register with FinCEN. Also criminals will structure their microtransactions across multiple anonymous user accounts to side-step limits, thus your point really does not apply.
The aggregator not the merchants could be an MSB and would be a "Seller of Prepaid Access" so the following applies:
https://www.fincen.gov/news_room/nr/html/20111102.html It would likely fall into the closed loop exception if the merchants / publishers are vetted as legit. The limit is this case is 2000 USD in loads per day and I am talking of 10 USD per load.
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Yes. Credit cards can be incentivize massive fraud especially if they can pay themselves as merchants.
But the scaling problem of centralized ledgers is just as onerous an issue too.
Yes but as I mentioned above this can be addressed by having many centralized ledgers.
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Now you understand why a centralized ledger (and a centralized aggregator of funds) will never scale nor work in practice due to FinCEN requirements to avoid criminal structuring.
The due diligence is done on the payment end. If someone tries to use this to launder money it would be easily apparent by looking at the click patterns on the front website much like click fraud is currently detected. So if there is something clearly amiss the aggregator can detect this, and file one rather than millions of suspicious activity reports.
By the way I have been involved with web based advertising as a publisher for well over twelve years so I am familiar with this business. What I am suggesting simply replaces the advertising component with a pay per page view component for a comparable yield to the publisher.
Edit: Closed loop prepaid access can also work well for in person transactions since it only has to deal with one jurisdiction making compliance very simple even if registration is required. This is the critical advantage of separating this from the actual coin protocol. A very good example why this kind of separation works very well is Bitcoin ATMs since the operator only has to deal with one regulator namely that where the Bitcoin ATM is located.