As you are not touching the funds, this does not make you a money services business and hence, registration with FinCEN is not required (this is our opinion, however, IANAL: I am not a lawyer, so please see professional legal advice). Your payout partner (may, and we are not experts in this opinion) may be required to register with FinCEN, but under the general RAAS offering, FinCEN registration is not required.
-  FinCEN MSB Definition for Transactions Under $1000 Per Person Per Day
-  FinCEN Registration & Money Transmitter Licenses
-  Why FinCEN Registration is NOT a License?
-  Is FinCEN Registration Free or Not?
This page was last updated on January 18, 2023.