Global Client Solutions, one of the major escrow companies that handles funds for debt settlement clients, was charged with being
an unlicensed money transmitter by the state of Connecticut and then entered into a consent order to...
«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.