The Financial Crimes Enforcement Network (FinCEN) has released two administrative rulings on virtual currency, addressing the application of FinCEN regulations to a virtual currency trading platform and a virtual currency payment system.

The rulings were in response to letters dated December 3, 2024 and January 6, 2014, asking about a certain company’s possible status as a money service business (MSB) under the Bank Secrecy Act (BSA).

The letters asked if creating a virtual currency trading and booking platform, which will match buyers and sellers on the platform, and a convertible virtual currency payment system will make a company a money transmitter.

In the two rulings, FinCEN, a bureau of the US Department of the Treasury that gathers and analyzes information on financial transactions to fight financial crimes such as domestic and international money laundering, and terrorist financing, said the company will become a money transmitter pursuant to its regulations.

FinCEN cited its 2011 amendments, which defines money transmitter as a person that provides money transmission services, or any other person engaged in the transfer of funds.

As money transmitters, companies are required to comply with all risk management, risk mitigation, record keeping, reporting, and transaction monitoring requirements, FinCEN said.

It remains to be seen how this new ruling will affect the growing virtual currency world and how virtual currency providers conduct business, but U.S.-based bitcoin businesses may face additional challenges in becoming money transmitters within regulated states.