Comment: Doesn't apply in many ways

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Doesn't apply in many ways

Government bureaucrats will always try to change the law to whatever they want under color of law, and Obama likes to do things through decree instead of actual congress, so this is expected - but will have zero effect other than possibly some government terrorism (ie enforcing non-laws through military, police force) as they've done in the past.

Working through the courts, and not going through all the legal arguments made - since this is being applied to existing institutions and businesses, it would REQUIRE AN ACT OF LEGISLATURE to be valid.

But leaving aside that, it:
a) only effects people who exchange bitcoins for currency - which bitcoins can be a completely separated thing from any currency.
b) are in the United States. Bitcoins is everywhere, hard to trace, and any business that needs a physical presence can be outside the United States. Large corporations do it all the time. It is not necessary to operate in the United States.

It also doesn't apply to gift cards, which is one of the common things bitcoins are exchanged for.

These regulations will have zero effect on bitcoin other than for many people to ensure that they don't operate in the United States - which was already the motivation of most users to begin with.

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However, an administrator or exchanger is an MSB under FinCEN’s regulations, specifically, a money transmitter, unless a limitation to or exemption from the definition applies to the person."

They explain the terms here, "This guidance refers to the participants in generic virtual currency arrangements, using the terms “user,” “exchanger,” and “administrator.”6 A user is a person that obtains virtual currency to purchase goods or services.7 An exchanger is a person engaged as a business in the exchange of virtual currency for real currency, funds, or other virtual currency. 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 for the support of this Declaration, with a firm reliance on the protection of Divine Providence, we mutually pledge to each other our lives, our fortunes and our sacred honor.