This is a little dated, but I thought it was important to share. On January 30 2014 the Financial Crimes Enforcement Network (FinCEN) published two administrative rulingsregarding whether companies engaged in certain 'mining' software development and investment activities with respect to virtual currencies must be registered as a money services business under the regulations promulgated by FinCEN under the Bank Secrecy Act. While regulators are continuing to develop positions on virtual currency activity, these rulings provide useful insight on how FinCEN is likely to interpret the regulations and the recent virtual currency guidance with respect to various activities in the virtual currency markets.
