Bitcoin Forum

You can check here: http://www.fincen.gov/financial_institutions/msb/msbstateselector.html

I found Bitfloor, Coinbase and Coinlab. No CampBX.

Well, hopefully CampBX has their application pending.

Not an exchange more like a broker but Tangible Cryptography is also registered as a MSB.

Did you try "bulbul investments llc"? I believe that's the name CampBX is actually incorporated under.

Yes I did.

Shouldn't BitPay be registered?  ???

Don't you have 180 days from establishing an MSB to complete the registration? IIRC it says that right on the application.

BitFloor is dead.

It could come back, only been offline a couple weeks :p

Their license still in good standing.

They're not an exchange so they're probably OK.

Here's their take on it:
http://blog.bitpay.com/2013/03/how-fincen-guidelines-affect-bitpay.html?m=1

Www.bitbox.mx is a us exchange that's registered. I've discussed it with them.

They are registered but only in one State.

Michigan right?

I wonder if Michigan requires you to register in every state you do business in. Someone explaining this all to me had aid some states just require registration in your primary state or something like that.

Any idea?

Registering in one State does not give an exchange the freedom to conduct business in every other State. Bitbox must be in compliance with each and every State where it is conducting business.

I don't understand how any bitcoin exchange can maintain that they are only conducting business in a home/primary State while they are knowingly serving residents across borders. I suppose the exchange could establish procedures to filter residents. For example, not allowing unverified accounts and only approving accounts of residents where the exchange is registered. But, this policy would severely cripple an exchange's ability to compete with other exchanges that are registered in every State.

Every bitcoin exchange should be seeking registration with every State. Simple as that. It might be expensive and time consuming, but that's the cost of running a money services business that extends across State borders.

Thank you for the link  :)

The problem doesn't end there, because if they don't have a way of filtering where their users live then they'll potentially be doing business in all kinds of other countries, and breaking their laws as well.

The ideal solution would be to get the necessary permits for every jurisdiction in the world, but this may not be practical - for example, there are a lot of countries where PayPal can't do business, presumably not for lack of trying.

I think the upshot is that (above-the-radar) exchanges will need some way of filtering their customers by jurisdiction. IANAL, but it may be enough just to geolocate their IPs and ask them to promise that they're in one of the places where the exchange is licensed. Once they've done that, there's no particular need to operate everywhere in the US either. It may actually be less risky to have a lot of little exchanges in different states rather than one big national one, so you don't risk getting everyone's service disrupted because you messed up the paperwork for North Dakota or whatever.

Yes you do, but registering with FinCEN is not going to be sufficient for most MSBs - they'll also have to register at state level and the requirements for doing that can be considerable.

Looks like CampBX (bulbul investments) just became FINCEN registered. The CEO has an MBA for god's sake, I should hope he knows what he's doin!

https://bitcointalk.org/index.php?topic=163978.msg2199736#msg2199736