Ok, doing some googling I see this:

https://themerkle.com/is-it-legal-to-run-a-bitcoin-faucet-as-us-citizen/

I take it this is still current?  Any thoughts about running a "faucet-like-service" in California vs New York?

Are you saying faucets don't generally need to worry about running into problems with the KYC/AML laws mentioned by cellard?  I don't know much about faucets.. eg, do they usually run "above-board" in the US, or do they usually run offshore and try to evade US law enforcement?

I was thinking that if that were the case, I could collect store users' IP addresses, and even ask for their email addresses in order to have something to show if any law enforcement was suspicious of the payouts being used for money laundering or otherwise illicit purposes.

Thanks for the thoughtful reply!!


Yeah exactly.  It would be paying people a reasonable amount of money for their time to give valuable market feedback.  For example, giving them $5 worth of crypto for filling out a survey that might take them 5-10 minutes.


When you say huge amounts of money, do you mean overall or transacting with a single individual?  It should always be a low amount ($5 / survey) per individual recipient, but if the site became popular then it could add up to a lot of money.  I guess maybe the answer is that if the site starts to become popular, go hire a lawyer?


Would they be any more complicated that for a site like Pinecone Research that is probably paying out millions to fill out surveys?  I guess my real question is: are there any additional legal complications to paying out in cryptocurrency vs paying out in paypal or other means?  (maybe I should also research the legal implications of simply reimbursing people for filling out surveys via PayPal as opposed to with cryptocurrency)

It seems to me like there shouldn't be, as long as the system can't be abused for money laundering or criminal activity, which is what the Fincen money transmitter laws are trying to prevent.  Since the website would have an incentive to make sure that the users gave thoughtful responses, since otherwise the survey responses would be useless, it would be an effort along the same lines of preventing potential criminals that want to accumulate anonymous money for illicit purposes.

I guess as long as someone is working to earn money, it can't be money laundering.  And so I can't see how Fincen or anti-money transmitting laws would be relevant to this.

I was thinking about setting up a website that would ask people to anonymously fill out online marketing surveys and would reimburse them with a small amount of Litecoin for their time. They would just need to provide a public wallet address to receive the payment. It would be similar to PineconeResearch where users receive $3 for filling out a 10 minute survey, but w/ cryptocurrency instead of Paypal or Virtual Visa Debit cards.

If the servers are based in California and the website is sending money to anyone in the world, would this run into any money transmitter license issues with US Fincen or CA state laws?

As far as I understand, you're only considered a money transmitter if you're selling money. Businesses that take payment in cryptocurrency don't need a money transmitter license, and I'm assuming that businesses that are remitting payments in cryptocurrency don't need one either... or is it more complicated than that?