My foreign-owned LLC collects payments from customers and pays freelancers — am I a money transmitter?
I own a foreign-owned LLC that runs a freelance marketplace platform. Clients pay my LLC for projects, and then my LLC pays the freelancers after taking a commission. A lawyer friend warned me that this might make my LLC a 'money transmitter' under FinCEN rules, which would mean I need a special license. My LLC is just a marketplace. I am not a bank. Am I really a money transmitter? What happens if I am operating as one without a license?
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