Question regarding a potential business client:

Client stated that he is a broker/seller of bit-coin (not the main business). His clients pay with cash (to which he is understands the reporting requirements that come with that) then he makes the purchase through an (administrator) company.

I've been researching extensively and just when I think I am certain of his requirement, I read something that makes me second guess it (I call it the "BSA Merry-Go-Round")…..

I am leaning toward him being a Money Transmitter that falls under that "Facts and circumstances; Limitations" category. Making him exempt - acting on behalf of the true MSB (aka the administrator I mentioned) - that would need to be registered with FinCen (which they are, I checked).

Am I correct in this thinking? If not, please advise.

Thank you!

Did you see this on the BOL penalties page?

Currency Transmitter Fined

I had not but I had referred to the FinCEN Guidance it mentioned. Perhaps I was reading/interpreting it incorrectly. This article makes it more clear.

Thank you.