Is Ripple a money transmitter under FinCEN regulation? Do they have a Money Transmitter license?

by Joao Leme   Last Updated November 28, 2018 14:27 PM

FinCEN guidance states that

"An administrator is a person engaged as a business in issuing (putting into circulation) a virtual currency, and who has the authority to redeem (to withdraw from circulation) such virtual currency."

and

"an administrator or exchanger of convertible virtual currencies that (1) accepts and transmits a convertible virtual currency or (2) buys or sells convertible virtual currency in exchange for currency of legal tender or another convertible virtual currency for any reason (including when intermediating between a user and a seller of goods or services the user is purchasing on the user’s behalf) is a money transmitter under FinCEN's regulations"

From my understanding, Ripple, as well as Stellar, are money transmitters because they are administrators and sell convertible virtual currency in exchange for currency, BUT, as I've seen so far, Ripple has registered with FinCEN as an MSB, but not specifically as a money transmitter.

Also, as a money transmitter, it is required to get licenses at each state as well.

Am I missing something?

Thanks in advance!



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