What about state regulators? We only planned for a federal analysis.

State law is where most of the licensing burden sits, and it is keyed to customer location, not company location. Modern statutes define “control” as the power to execute unilaterally or prevent indefinitely a virtual currency transaction — language enacted in states including Louisiana and Minnesota, and matched by California’s Digital Financial Assets Law. A platform that can execute the payout, or refuse to, holds that power by design. New York’s BitLicense covers receiving virtual currency for transmission and maintaining custody or control on behalf of others. And any fiat leg — money in from the sender or payout to the recipient — is classic licensable money transmission in essentially every state. (URVCBA § 102(3)(A); La. R.S. 6:1382; Minn. Stat. § 53B.69; Cal. DFAL; 23 NYCRR § 200.2(q))