«Any group or individual developer who both (A) sold newly created tokens to buyers (i.e. had an ICO) involving U.S. residents and (B) failed to register with FinCEN as a money transmitter, and perform the associated compliance KYC / AML obligations, can be charged under a federal felony criminal statute, 18 U.S.C § 1960, with
unlicensed money transmission.
A bitcoin trader on exchange platform LocalBitcoins and his father have been sentenced to prison terms after being convicted of running
an unlicensed money transmission business.
These counts include: Conspiracy to Operate an Unlicensed Money Transmitting Business, Conspiracy to Launder Monetary Instruments, Operation of an Unlicensed Money Transmitting Business, and Operation of
an Unlicensed Money Transmission Business.
In June 2013, Bitcoin Foundation board member Jon Matonis wrote in Forbes that he received a warning letter from the California Department of Financial Institutions accusing the foundation of
unlicensed money transmission.
The primary charge against him is that he has been conducting
unlicensed money transmission without reporting it to the US Government.
Not exact matches
Failing to do so would be termed as an
unlicensed transmission of
money, which is illegal in the US.