We may have crossed into money transmission last quarter. Does the FinCEN registration clock really start that fast?
Our crypto app originally launched as a wallet tool, but after a product change we now routinely receive digital assets from one customer and transmit value to another. Only now is the legal team telling us that we may have become an MSB. That creates immediate anxiety because no one budgeted for registration and AML rollout in the original launch plan.
What I need is the deadline rule itself. If FinCEN really expects registration within 180 days after the business becomes an MSB, then we need to treat this as a present compliance deadline instead of an eventual licensing project.
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