You should read up on Suspicious Activity Report requirements.
You probably need to know at minimum name, address, and DOB for every account holder. If people can generate anonymous accounts and transfer thousands of dollars between them, your AML plan portion of your MSB application probably isn't going to be approved.
I am rooting for you, but I don't see how you will be able to get a MSB license in the US.
Thank you for your guidance.
Actually we have a team (lawyer, consultant etc.) that is working on this so i guess they will look into it as deep as it needs to go. I am no expert in this so i am just pointing out the steps we are taking or will take in the future by regularly updating the thread with our moves.
What you mention above is definitely going to be the case within the exchange. I actually pointed our team to Mt.Gox and the AML regulations they follow. They are also looking at other similar services and taking advice from much more experienced lawyers in this area.
You will need to follow AML procedures for both the exchange and transfers of funds across individuals via the client. To do this, you will need to link all payment addresses to verified identities and addresses. If anyone attempts to buy or send money using RealPay without verifying their identity, you will have to refuse the transfer, freeze their funds, etc. If your lawyer has told you don't need to do this, they may be incompetent.
You cannot administer an anonymous USD payment system for drugs, weapons, and human trafficking. This will never be allowed, don't kid yourself. Would governments like this? If the answer is no, then why would they choose to allow it? If they don't want to allow it, how can you force them to?
It could still work however if the peer-to-peer system has lower overhead than something like paypal and thus can allow users to earn interest, pay low fees, etc. If you think this is possible, then you should pursue your project. Just give up on anonymity because it is a pipe dream.