We have a prospect customer that wants to open an account for an investment company that holds alternative investments (bitcoin). They own the bitcoin in a third party brokerage firm. They purchase bitcoin to hold for a long term currency investment. They will not trade bitcoin or use it to purchase goods or services. Would that still make them a MSB? Thank you.

And what is the relationship between this "prospect customer" and the "investment company"? Holds the bitcoin investment for whom. If they don't trade, what do they need a bank account for??

We have just recently opened an account for a customer who is a bitcoin trader (our first). They have also opened up a second account, under a different business name with different EIN, which is an investment fund for those who want to purchase very large amounts of bitcoin. While we are currently looking into this, THEY (our customer) claim, per FinCEN, the secondary account/business is not considered a MSB. The only reasoning I can come up with is they are not actually receiving the bitcoin at the time, but the money is placed in the account to be used by the company to purchase future bitcoin? rlcarey, I'm having trouble understanding this as well. There seems to be more questions than actual answers. I'm contacting FinCEN today, and will let you know what answer(s) I receive.