Hawaii’s New Money Transmitters Act Will Require Virtual Currency Licenses

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Most of the world would consider you a friend doing a friend a favor, the U. How can this be? An MSB includes any person doing business whether or not on a regular basis or as an organized business concern that operates as, among other things, a money transmitter. A person or entity that acts as a money transmitter will be required to, among other things in addition to state money transmitter licensing requirements:.

Recently, and on an increasing basis, both federal and state agencies are criminally charging individuals who operate illegal money transmission businesses by selling cryptocurrencies.

Ina grand jury in Arizona indicted two men with operating an unlicensed money transmitting business over the course of four years. There, the defendants conducted over transactions, indicating that they were engaged as a business in circulating virtual currencies. Similarly, in Aprila New York man pled guilty after being charged with operating an illegal money transmission business, which ultimately conducted over transactions both locally and throughout the United States.

There is hope, however, for the friend being a friend. In a recent Florida case, a trial court dismissed charges against a man who was arrested and charged with operating an unlicensed money transmitting business. What does this mean to you? This may be a good qualification under applicable State law, but FinCEN seems to be taking the approach that any exchange for any reason is sufficient. So, just stop it. The risk is too great.

Bitcoin exchange money transmitter activity those interested in buying cryptocurrencies to legitimate sites that are licensed as MSBs. This is a limited exemption and you should discuss with legal counsel if you have any questions.

Michael Best has an integrated team that works with clients in the cryptocurrency, ICO, and blockchain space. We assist in securities, investment, Bitcoin and other cryptocurrencies, intellectual property, privacy and security, blockchain implementation, and other matters in this space. You are commenting bitcoin exchange money transmitter activity your Bitcoin exchange money transmitter activity.

You are commenting using your Twitter account. You are commenting using your Facebook account. Notify me of new comments via email. A bitcoin exchange money transmitter activity or entity that acts as a money transmitter will be required to, among other things in addition to state money transmitter licensing requirements: Leave a Reply Cancel reply Enter bitcoin exchange money transmitter activity comment here Fill in your details below or click an icon to log in: Email required Address never made public.

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We use cookies to improve the functionality of our products and services, and enhance your experience on our website. If you continue without changing your cookie settings, we assume you are happy to receive all cookies on the website. However, you can change your cookie settings anytime. Read our Cookie Policy for more information.. If you have a complaint or other concern about Alaska money services licensees, authorized delegates, and the money services provided by money services licensees and authorized delegates, you may contact the Alaska Department of Commerce, Community, and Economic Development, Division of Banking and Securities at If you have a question or complaint, please contact the consumer assistance division of Coinbase at https: Louisiana Please note the license issued to Coinbase by the Louisiana Office of Financial Institutions does not cover the exchange or transmission of virtual currency.

New York Please note the following disclosures associated with virtual currency: Nevada Coinbase is licensed by the Nevada Department of Business and Industry as a money transmitter. At this time, the Nevada Department of Business and Industry does not license or regulate services related to virtual currency, including but not limited to virtual currency transmission or exchange which may be conducted by Coinbase. Tennessee Please note that this license and the required surety bond do not cover the transmission of virtual currency.

Coinbase is licensed by the Tennessee Department of Financial Institutions as a money transmitter. The Tennessee Department of Financial Institutions does not regulate virtual currency. Texas If you have a complaint, first contact the consumer assistance division of Coinbase at https: If you still have an unresolved complaint regarding the company's money transmission or currency exchange activity, please direct your complaint to: Sale of Checks License, SC Arizona Department of Financial Institutions N.

Money Transmission License, Sale of Checks and Transmission of Money, Office of the State Bank Commissioner E. Florida Office of Financial Regulation E. Gaines Street Tallahassee, FL Seller of Payment Instruments License, Money Services License, State of Iowa Division of Banking E.

Money Transmitter License, SC Money Transmitter License, View Disclosure. Money Transmitter License, MD Money Transmitter License, C Money Transmitter License, North Carolina Commissioner of Banks W. Edenton Street Raleigh, NC Money Transmitter License, TM Money Transmitter License, MT. License Number View Disclosure.

Box Richmond, Virginia Money Transmitter License, MT Please note that this license does not cover the transmission of virtual currency. Please note the license issued to Coinbase by the Louisiana Office of Financial Institutions does not cover the exchange or transmission of virtual currency.

Please note the following disclosures associated with virtual currency: Coinbase is licensed by the Nevada Department of Business and Industry as a money transmitter. Please note that this license and the required surety bond do not cover the transmission of virtual currency.

If you have a complaint, first contact the consumer assistance division of Coinbase at https: