As I weigh my own bitcoin-based startup plan, I’m trying to wrap my head around the new (U.S.) FinCEN directives. Specifically, I’m interested in the tip-bot problem. That is, any person or business who accepts virtual or real currency, holds it for any amount of time, and later disburses it to another user is considered a “Money Transmitter” and required to do all the federal and state registration and licensing. The product that I am considering building performs a similar function, and if I have to get state-licensed, I’m just going to abandon the idea altogether.
What I’m curious about is if I can use the API of someone like Coinbase or CoinX, who is already state-licensed, to effectively hand off the FinCEN responsibilities, while I build and operate the customer-facing service.
I’d love for some knowledgeable folks to comment, since I can’t be the only one facing problems like this. Money transmitter regulations are going to put a huge damper on any virtual currency business development, and at least for the US, put us at a large disadvantage to other countries.