Venezuela: USD/VES Money Transmission, Netting & Licensing (FK-V004, Faisal Khan LLC) is a structuring framework for the US–Venezuela corridor, covering classification, netting, licensing, sanctions and liquidity — explicitly not a legal opinion or sanctions clearance, and built around Binance P2P retail flow rather than B2B.
The paper's central test: "the question is not whether the funds physically touch the operator's bank account. The question is what the operator actually does." An operator running rate-setting, matching, beneficiary direction, spread capture, liquidity management and exception management is a money transmitter in substance, even keeping funds outside its own LLC account — and the practical sponsored route is becoming an Authorized Delegate under a Principal License Holder.
The most useful number: roughly $200,000 a month is treated as commercially insufficient for a credible Venezuela PLH program, since even 40 basis points produces only $800 in gross revenue before fixed fees. The guide cites roughly $2 million a month as a practical engagement threshold, with established corridor operators processing $12–30 million monthly.
On netting, the paper is blunt that offsetting opposite obligations is a settlement technique, not a regulatory exemption, and lists seven conditions — including full reconciliation and licensed endpoints — that make it defensible. On P2P liquidity, it warns that personal bank accounts used for business settlement, cash couriers, and unhosted wallets with unknown ownership are program-stopping features, concluding "P2P liquidity is not a replacement for licensing."
What the guide covers:
- Indicative setup and monthly costs for API/non-agent versus Authorized Delegate structures
- OFAC's active Venezuela sanctions program and the limits of personal remittance general licenses
- A Canadian alternative route, costed at $30,000–$60,000 and four weeks to ten-plus months
- The ten-workstream readiness checklist and eight-step launch sequence
- Why FinCEN registration does not replace state money-transmitter licensing