I would like to make some observations after reading the article ‘Virtual Currencies Draw State Scrutiny’ by Robin Sidel and Andrew Johnson in the Wall Street Journal. The newly virtual currency exchanges must have developed a business plan specifying in detail the type of financial service which they planned to provide. In addition, as in many cases these firms could have used attorneys to legally incorporate their businesses. Whether it should have been the relevant attorneys, their bank officer who opened their bank accounts or the owners – it appears that the money transfer experts were not consulted.
Those of us in Money Transfer Compliance would have easily recognized that a money transfer license would have been necessary for the Bitcoin type of business module. And even if the activity was in a ‘grey area’ – a simple call to the U.S regulators would have solved the issue. In any case, one cannot go back in time but must deal with current reality – which is a Money Transfer license is required for a given relevant state in the U.S.A. Yes – it is a bit cumbersome to obtain a license state by state since we do not have in place one National Money Transfer license covering the entire United States.
However, to attain a state Money Transfer License is relatively painless if you consult with the Money Transfer experts. We can apply for one or multiple state licenses at a given time for a reasonable price and not a huge fortune. And you do not need an attorney to execute this task. Leave it to the experts who have the experience in this field.
And please – as long as the virtual currency exchanges have an objective of only conducting legitimate business then they should welcome the anti-money laundering requirements which come along with a state Money Transfer License. Again the money transfer regulatory experts can assist you to set up policies, procedures and controls to mitigate the infiltration of the criminal elements in your company operations.
Yes – you do need surety bonds for the Money Transfer licenses in the various states. But do not be afraid of the numbers – such as having to obtain a surety bond of $300,000 to $2 million. Again the money transfer compliance experts can have the surety bond specialists quote you the premiums which you will need to pay – and I assure you that if your company has a good business, those premiums can be quite satisfactory.
So please my friends – do not be afraid. Be brave – especially if you have confidence in your product and service and wish to conduct only legitimate business. The government regulators will work with you as long as you follow the rules.