After a bit more digging I found this in the FATF proposal.
https://static.coindesk.com/wp-content/uploads/2019/06/Embargo-Virtual-Asset-Guidance.pdf"c) “Virtual asset service provider” as any natural or legal person who is not
covered elsewhere under the Recommendations and as a business conducts
one or more of the following activities or operations for or on behalf of another
natural or legal person:
i. Exchange between virtual assets and fiat currencies;
ii. Exchange between one or more forms of virtual assets;
14 │ GUIDANCE FOR A RISK-BASED APPROACH TO VIRTUAL ASSETS AND VIRTUAL ASSET SERVICE PROVIDERS
© 2019 | FATF
iii. Transfer4 of virtual assets; and
iv. Safekeeping and/or administration of virtual assets or instruments
enabling control over virtual assets;
v. Participation in and provision of financial services related to an issuer’s
offer and/or sale of a virtual asset.
34. Notably, the scope of the FATF definition includes both virtual-to-virtual and virtual-to-fiat
transactions or financial activities or operations.
35. Depending on their particular financial activities, VASPs include VA exchanges and transfer
services;
some VA wallet providers,
such as those that host wallets or maintain custody or
control over another natural or legal person’s VAs, wallet(s), and/or private key(s); providers
of financial services relating to the issuance, offer, or sale of a VA (such as in an ICO); and other
possible business models. "
Sadly after reading more of the FATF bullshit I realize that my favorite Bitcoin sports gambling sites Nitrogensports.eu and many other sites that never feared much from regulators due to never using fiat could be in for a lot of shit.