Similar to the early days of the virtual currency of 📝Second Life, the implementation of 📝Cash Distribution Agreements brings with it some potential regulatory hurdles we need to be aware of as we grow. I know enough to be dangerous on these subjects from Second Life, where we shut down in-world gambling, and from developing TrustEgg.com. What follows is my view as an operator, not legal advice.
- Money Transmitter Rules - in the US, businesses that transmit money may need to register with FinCEN as a money services business as well as obtain state licenses.
- Know your Customer (KYC)
- Anti Money Laundering (AML) - the Bank Secrecy Act requires financial institutions to keep records, report large cash transactions, and report suspicious activity that may signal money laundering.
- Acting as a Depository
- Taking on the Fiduciary Obligations of an Escrow Company
There are various levels of compliance that we will address at each stage of our growth, following the PayPal approach: grow fast first, address regulatory issues when there is cash to do it.