Here, I think, there is a better argument to be made in that the definition of money transmitter business requires a “party” to be sending and/or receiving currency. If you dig into what that actually means, we’re likely going to end up with a definition like this, from the Code of Federal Regulations: “an individual, a corporation, a partnership, a trust or estate, a joint stock company, an association, a syndicate, joint venture, or other unincorporated organization or group, an Indian Tribe (as that term is defined in the Indian Gaming Regulatory Act), and all entities cognizable as legal personalities.”
May 07, 2024
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