FAQ: Cryptocurrency & Blockchain

• A smart contract moves the money, not us. Do we still need a money transmitter license?
• Can Stablecoins or Crypto Improve Our Payments Model?
• Does using a smart contract instead of a bank account change the legal analysis?
• Has anyone actually been prosecuted over a “non-custodial” model?
• How many Layers are in a Blockchain?
• Is a money transmitter license adequate for launching crypto-related services in the US?
• Is banking for Bitcoin ATM business done through direct bank relationships or an intermediary?
• Is handling crypto-currency already included in the pre-built application?
• Is there an exemption that covers this model?
• Marketplace with the Most Liquidity
• So what does a compliant path actually look like?
• Uniswap and other DeFi apps operate without money transmitter licenses. Why can’t we do the same?
• We never take custody. Isn’t “non-custodial” enough to avoid licensing?
• What about state regulators? We only planned for a federal analysis.
• What are Rollups
• What does FinCEN say about apps built on smart contracts specifically?
• What does it mean when someone says they are "farming us" (or “farm us”) in the crypto space?
• What happens if we launch anyway and deal with licensing later?
• What if we redesign it so the customer’s own wallet signature releases the funds?
• What is cryptocurrency-as-a-service?
• Which blockchain can you deploy an exchange-traded fund (or EFT) on?
• Why does the gas fee in the cryptocurrency world fluctuate while transaction fees in the fiat world remain fixed?
• Why is understanding IRS Title 31 Audit crucial for BTM operators?