This is moot point if US clients are involved (IMO, not legal advice):
https://bitcointalk.org/index.php?topic=155563.msg1652737#msg1652737MSB/MT registration, as annoying as it is, is by no means insurmountable. On the contrary, it looks to be fairly easy. The AML requirements are NOT a big deal. If it's the same AML requirements that investment funds and brokerages must complete, one simply takes a yearly online test (fill in the blank, not really a test at all). Record keeping is not daunting.....it all sounds much more ominous than it is. I say this without having direct experience with MSB/MT regulations. I do know a little about the fund world, though. MSBs may have a slightly different set of requirements....