
FinCEN's guidance on crypto business models: are you a money transmitter? - davidgerard
https://davidgerard.co.uk/blockchain/2019/05/09/fincens-guidance-on-crypto-business-models-are-you-a-money-transmitter/
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crwalker
I am hardly a fan of Gerard but this is a well written summary of the
guidance.

The only thing I would add to clarify money transmission as "transmitting
value that substitutes for currency" is that exchanging funds for goods
(normal commerce e.g. buying a coffee with credit card / cash / apple pay /
stablecoin) is probably not considered money transmission. But I'm not your
lawyer.

