The guidance said a user spending convertible virtual currency was not a money-services business solely for that activity. Administrators and exchangers could be money transmitters subject to registration, reporting, and anti-money-laundering obligations.
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FinCEN issues virtual-currency guidance
The U.S. Financial Crimes Enforcement Network distinguished ordinary users from administrators and exchangers under money-services rules.
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IN THE SHOWThe Long Arm of the Law