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1441  Bitcoin / Press / Re: NEW articles in Press Forum on: March 19, 2013, 06:39:14 PM
2013-03-19 BitcoinFoundation.org - Today, we are all money transmitters…
https://bitcointalk.org/index.php?topic=155010.0
1442  Bitcoin / Press / 2013-03-19 BitcoinFoundation.org - Today, we are all money transmitters… on: March 19, 2013, 06:38:31 PM
By Bitcoin Foundation general counsel Patrick Murck

Upon an initial reading two things struck me:
FinCEN firmly believes that virtual currency in general, and bitcoin in particular, does not fall under the pre-paid access rules.
FinCEN seems intent on recreating and expanding the pre-paid access rules for virtual currency and bitcoin under the mantle of money transmission.
[...]
Under the Administrative Procedures Act (APA), FinCEN can’t promulgate new rules without going through a notice and comment proceeding whereby the public may have their voices heard. If FinCEN would like to expand its statutory authority over “money transmitters” to include brand new categories such as 'administrators' and 'exchangers' of digital currency it must do so through proper rulemaking proceedings and not by fiat.
[...]
FinCEN’s guidance implies that every person who has ever had any virtual currency and has ever exchanged that virtual currency for real currency may now be considered a money transmitter under the Bank Secrecy Act. That is, of course, an untenable position.
[...]
This framework would wildly expand the reach of FinCEN and the BSA, and would be infeasable for many, if not most, members of the bitcoin community to comply with.  [...] The BSA was never intended to apply this broadly and reach this far into people’s everyday lives.

 - https://bitcoinfoundation.org/blog/?p=152
1443  Other / Beginners & Help / Re: btc-e vs mtgox price influence on: March 19, 2013, 05:18:18 PM
if btc-e dies, would mtgox cause the price to increase?

Not sure, as both happens so frequently I don't know if you could determine if correlation is causation.
1444  Economy / Speculation / Re: Parity watch -> Malawi on: March 19, 2013, 05:14:46 PM
It appears Bitcoin's M1 is already higher than M1 of the following countries:

That's getting serious.
1445  Other / Beginners & Help / Re: Newbie time required not shown on: March 19, 2013, 05:13:12 PM
what is considered "time spent online?" How is that calculated?

Activity keeps your session alive, and it notices inactivity after a few minutes.  So if you only navigate once an hour for four hours, you'll get like twelve minutes of time logged.

There is a whitelist request thread, you can post there but your request probably needs to be meritorious versus just chasing the Ripple handout.
1446  Bitcoin / Bitcoin Discussion / Re: FinCEN addresses Bitcoin on: March 19, 2013, 02:51:50 PM
Incidentally,

AML specialists are hard at work this week for the moneylaundering.com 18th Annual International AML & Financial Crime Conference at the Westin in Miami:





 - http://www.moneylaunderingconference.com/2013/default.asp

They might be overjoyed to learn that through this guidance FinCEN found some new meat to help them generate some billable hours that well allow them to make it through these lean times.
1447  Bitcoin / Project Development / Re: ICBIT Derivatives Market (USD/BTC futures trading) - LIVE on: March 19, 2013, 02:39:26 PM
As I have negative initial margin it doesn't allow me to send orders which would close my position.

If that is correct, that's new-ish.
1448  Other / Beginners & Help / Re: I am a certified Anti-Money Laundering agent. (AMLCA) on: March 19, 2013, 01:49:09 PM
The general understanding is that a merchant selling goods and services and accepting bitcoin as payment is not an exchange or money transmitter.

Is this a safe assumption because:

Quote
FIN-2013-G001

An exchanger is a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency

 - http://www.fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html

and the mechant is not engaged in the exchange so therefore isn't an exchanger?


Or, is it because:

Quote
31 CFR § 1010.100(ff)(5)(ii)(F):

The term “money transmitter” shall not include a person that only:
(F) Accepts and transmits funds only integral to the sale of goods or the provision of services, other than money transmission services, by the person who is accepting and transmitting the funds.
1449  Economy / Trading Discussion / Re: bitcoins to AUD on: March 19, 2013, 01:23:49 PM
Here's a fairly comprehensive list of exchanges, a few in Australia:
 - http://en.bitcoin.it/wiki/Buying_bitcoins

I'm going to China for work soon

Incidentally, that must be about the sixth time I've heard from someone saying that or read about someone planning that in just the past week.
1450  Bitcoin / Development & Technical Discussion / Re: strange transaction on: March 19, 2013, 12:37:09 PM
Thanks, I did send 2 btc to another address and it was received ok. However the other inputs which were input correctly then (strangely) debited   remain a mystery as to how that happened?.

Well, technically you did not send 2 BTC.  

Instead, your client chose the following UTXO transactions and sent:
  1.2251 BTC, plus
  0.04516 BTC, plus
  0.575 BTC, plus
  0.15333002 BTC, plus
  0.00717549 BTC, plus
  0.00716474 BTC

Which all combined totals: 2.01293025 BTC.  From that you specified that 2.0 BTC of it goes to a certain address and then the change, 0.01293025 BTC came back to you at another address from your wallet.

Or are we somehow talking past each other here?
1451  Other / Beginners & Help / Re: Bitcoin-QT: System Error: Database Corrupted on: March 19, 2013, 12:23:12 PM
Any comments good/bad about Multi-Bit?

Well, the comment in red at the bottom should be understood:
 - https://multibit.org/help_walletManagement.html
1452  Bitcoin / Project Development / Re: ICBIT Derivatives Market (USD/BTC futures trading) - LIVE on: March 19, 2013, 12:20:29 PM
All they need to do is add "at 8pm" to the contract wording,

To me it was implied that settlement would occur at the end of the trading day (which ends at 20:00 UTC) at the VWAP at the time of settlement.  But I suppose that could be ambiguous so your point is valid.   It doesn't mention what duration of VWAP is used (24 hour) nor at what time it is taken (end of trading day) so including both of those would reduce any confusion.
1453  Bitcoin / Development & Technical Discussion / Re: BTC to mBTC in the main client on: March 19, 2013, 11:47:53 AM
I propose that we start by showing the amount in our wallets in mBTC. People should get used to the new denomination in bitcoin.

What do you guys think?

Well, that is optional for each user now.  Are you suggesting to change the default to mBTC?
1454  Other / Beginners & Help / Re: Bitcoin-QT: System Error: Database Corrupted on: March 19, 2013, 11:12:11 AM
I thought I'd simply uninstall and reinstall.

If you never used any addresses from your wallet, you can wipe the entire Bitcoin data directory and restart the client and it will re-create all the files it needs.
 - http://en.bitcoin.it/wiki/Data_directory

1455  Bitcoin / Bitcoin Discussion / Re: FinCEN addresses Bitcoin on: March 19, 2013, 09:06:15 AM
As long as I only occasionally sell my own Bitcoins I am not engaged as business. As I see it all of this does not affect private users.

There's also this exemption:

Quote
31 CFR § 1010.100(ff)(8 )

Limitation. For the purposes of this section, the term “money services business” shall not include:

(iii) A natural person who engages in an activity identified in paragraphs (ff)(1) through (ff)(5) of this section on an infrequent basis and not for gain or profit.
- http://cfr.regstoday.com/31cfr1010.aspx#31_CFR_1010p100

The only time I've seen a definition of "infrequent" was in this report from McGladrey in which the definition mentions "fives [trades] or less [per year] and not done for profit":
 - http://bit.ly/XYi9AF

Now that's for needing to register as an MSB.  That doesn't mean you aren't a money transmitter.
1456  Bitcoin / Bitcoin Discussion / Re: FinCEN addresses Bitcoin on: March 19, 2013, 06:20:20 AM
This is so full of loopholes.

Seriously.  

So, looking at this:

Quote
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.

I interpret that to mean that if I buy your bitcoins and give you dollars, I am "effecting a bona fide sale of the real currency"  (I sold you dollars).    So to me that means I'm not a money transmitter.



1457  Bitcoin / Bitcoin Discussion / Re: FinCEN addresses Bitcoin on: March 19, 2013, 05:27:19 AM
If you stick to selling under 1k a day

For clarity, that "$1K per-day" threshold is for use in determining if you would be considered a Money Service Business (MSB), and is not relevant in the discussion about whether or not an activity causes you to be considered a "money transmitter".

Quote
No activity threshold applies to the definition of money transmitter. Thus, a person who engages as a business in the transfer of funds is an MSB as a money transmitter, regardless of the amount of money transmission activity.

 - http://www.fincen.gov/financial_institutions/msb/definitions/msb.html
1458  Bitcoin / Bitcoin Discussion / Re: FinCEN addresses Bitcoin on: March 19, 2013, 02:37:39 AM
The anonymous BTC<-->USD exchanges are going to go two ways: Those that comply with FinCen and ask customers for full information

Yup.  There's really no way the exchange could prove the withdrawal was not to a third party.
1459  Bitcoin / Bitcoin Discussion / Re: FinCEN addresses Bitcoin on: March 19, 2013, 01:49:15 AM
Also an I Am Not A Lawyer (IANAL) disclaimer.

I was trying to figure if this applies to a hosted (shared) EWallet provider who holds customer's bitcoins and broadcasts bitcoin transactions, but does not convert to fiat or any other type of currency.

Quote
Administrators and Exchangers of Virtual Currency

An administrator or exchanger that (1) accepts and transmits a convertible virtual currency [,,,] for any reason is a money transmitter under FinCEN's regulations,

Because the EWallet provider isn't providing exchange to fiat or other currency (or value that substitutes as currency) the service is not a money transmitter.

That's good.


Quote
An administrator or exchanger that [...] (2) buys or sells convertible virtual currency for any reason is a money transmitter under FinCEN's regulations,

a.   E-Currencies and E-Precious Metals

Examples include, in part, (1) the transfer of funds between a customer and a third party by permitting a third party to fund a customer's account;

One example of this is an exchange that lets a customer have cash deposited into the exchange's bank account.  There's no way to prove the funds were the customer's funds and not some third party that had deposited for credit to the customer's exchange account.  

Because of the difficulties exchanges have had in offering that service I've just assumed that was a gray area.  But what if these funds are bitcoins and not dollars?  Does this mean an EWallet provider [Edit: exchange] needs to know that the bitcoins received to my wallet account came from me, and were not the result of a transfer I received from someone else?  That's the whole point of an EWallet .   This is unclear to me if this "no third party payments" restriction applies to bitcoin transfers as well.

Quote
(2) the transfer of value from a customer's currency or commodity position to the account of another customer;

That's the end of redeemable codes and account-to-account (A2A) transfers (unless, of course, the service providing it is an exchange and money transmitter).  But again, is this just for fiat funds, or do BTC transfers apply as well?

Quote
or (3) the closing out of a customer's currency or commodity position, with a transfer of proceeds to a third party.

So the cash-out services where the withdrawal goes to whichever bank account you provide would make them a money transmitter.  Or the ones that will cash out coins and send a Western Union money transfer or make a cash deposit to my bank account at my bank -- those are money transmitters according to this.
1460  Bitcoin / Development & Technical Discussion / Re: strange transaction on: March 18, 2013, 11:11:44 PM
background: the following transaction caused me to do a rescan (incorrectly). psy assisted me recover my client (detailed in tech support) and thought it would resolve this transaction. It did not! here it is:

 Status: 2130 confirmations
Date: 3/5/13 17:10
Debit: -0.04516 BTC
Debit: -0.00717549 BTC
Debit: -0.00716474 BTC
Net amount: -0.05950023 BTC
Transaction ID: e7fcb782ce3d36e5d33858ac112a1c29ce118f65a4f8ed25ee641e11050b6a8d

No send address for this amount was generated by me?. The "recent transactions box" shows an arrow both in and out? The transaction history shows just a debit for this in my client.

Would someone who is very very clever kindly have a look at this and offer an explanation as to how this occured?. If it can be recovered all the better but a rescan did not work? It is a small amount and if it is gone it is gone but if it happens again to a larger amount or to someone important it needs in principle to be understood!. regards reg.

This program uses Qt version 4.7.3.

v4.7.3 is so old.  I don't even remember what "arrow both in and out" would refer to. [Edit: That number of confirmations is what shows on your client, correct?  And that corresponds to the number of confirmations that show on Blockchain.info, correct?
 - http://blockchain.info/tx-index/58464860/e7fcb782ce3d36e5d33858ac112a1c29ce118f65a4f8ed25ee641e11050b6a8d
]

What is clear is that the blockchain shows those amounts spent and confirmed (in e7fcb782ce3d36e5d33858ac112a1c29ce118f65a4f8ed25ee641e11050b6a8d ), however the addresses those funds were spent from still have balances available for spending.

I'm not sure your familiarity with Bitcoin so let me describe something basic, in case you weren't aware.   You didn't have to spend 0.04516 anywhere for there to be a 0.04516 spend from your wallet.  The transaction in which those amounts were spent was for an amount of either 2.0 BTC or 0.01293025 BTC with the other one likely being change returned.

So if you didn't make that spend transaction on March 5th, 2013 then somehow somewhere your private keys are being used to spend, which could possibly mean a compromised wallet.dat or computer system (or both).   I've no idea if that's what happened but if you are saying you didn't spend either 2.0 BTC or 0.01293025 BTC on March 5th, 2013 then you should presume your system is not secure at this point.   [And the response to that is to use a different system that is secure, generate a Bitcoin address .. like using Blockchain.info/EWallet, and from your suspect system send your remaining funds to that address until you can rule out any chance that you have a wallet and/or system that is not secure.]
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