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Guidance FIN-2013-G001 Issued: March 18, 2013 Subject ...

Guidance FIN-2013-G001 issued : March 18, 2013 Subject : Application of FinCEN s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies The Financial Crimes Enforcement Network ( FinCEN ) is issuing this interpretive Guidance to clarify the applicability of the regulations implementing the Bank Secrecy Act ( BSA ) to persons creating, obtaining, distributing, exchanging, accepting, or transmitting virtual Such persons are referred to in this Guidance as users, administrators, and exchangers, all as defined A user of virtual currency is not an MSB under FinCEN s regulations and therefore is not Subject to MSB registration, reporting, and recordkeeping regulations.

In 2008, FinCEN issued guidance stating that as long as a broker or dealer in real currency or other commodities accepts and transmits funds solely for the purpose of effecting a . bona fide. purchase or sale of the real currency or other commodities for or with a customer, such person is not acting as a money transmitter under the regulations. 14

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