Fincen has released new guidance on what qualifies as a money transmitter. Some good, some bad. 👎Lightning nodes that charge a fee are likely money transmitters. 👍First I’ve seen from a US regulator that has a nuanced opinion on multisig. <a href="https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf">https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf</a>

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Christopher Allen

@ChristopherA

Fincen has released new guidance on what qualifies as a money transmitter. Some good, some bad. 👎Lightning nodes that charge a fee are likely money transmitters. 👍First I’ve seen from a US regulator that has a nuanced opinion on multisig. https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf

5/9/2019, 6:09:20 PM

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Christopher Allen

@ChristopherA

“If the multsig wallet provider restricts its role to creating un-hosted wallets that require adding a 2nd auth key to the wallet owner’s private key in order to validate & complete transactions, the provider is not a money transmitter because it does not accept & transmit value”

5/9/2019, 6:09:40 PM

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Christopher Allen

@ChristopherA

This is perfect for some multisig #SmartCustody wallets like @GreenAddress, and I think for @unchainedcap’s vaults https://www.unchained-capital.com/vaults/ but there are are some other custodial solutions that may not qualify…

5/9/2019, 6:13:20 PM

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Christopher Allen

@ChristopherA

“On the other hand, if the person combines the services of a multiple-signature wallet provider and a hosted wallet provider, that person will then qualify as a money transmitter.”

5/9/2019, 6:14:54 PM

Favs: 3

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