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#2262943 - 11/29/21 07:30 PM Virtual Currency and MSBs
Megaman Offline
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Joined: Jul 2017
Posts: 139
Is a bank customer that buys virtual currency (like Bitcoin) in an out of a bank account considered an exchanger and thus subject to MSB rules? For example: I buy bitcoin and treat it like a stock. I buy and sell the bitcoin (through a third party) but the money is debited and credited to my Bank account. Am I considered a virtual currency exchanger?

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#2262944 - 11/29/21 07:42 PM Re: Virtual Currency and MSBs Megaman
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,966
Illinois
No. You are considered a user because you are only buying and selling your own virtual currency. The third party that is selling you the virual currency would be an exchanger if it permits you to send virtual currency from your wallet to other wallets (thus acting as a money transmitter.)

FinCEN defines what is and is not an MSB in its 2013 Guidance.

https://www.fincen.gov/resources/st...incens-regulations-persons-administering

and 2019 Guidance

https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf
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#2263008 - 11/30/21 07:24 PM Re: Virtual Currency and MSBs BrianC
Megaman Offline
100 Club
Joined: Jul 2017
Posts: 139
Perfect thank you

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