What you are trying to do is referred to as an OTC (Over-the-Counter) Trading Desk. Whether you purchase the coins from an existing purse or from an exchange in real-time when the client purchases, the deal is the same (in our opinion), and in such a case you would be running/mimicking an OTC trade.
Any OTC trade like business requires that you:
- Register with FinCEN (Financial Crimes Enforcement Network)
- Under certain tokens/coins, you might need to have the regulatory licenses as offered by the SEC/FINRA (Please note, this is not our area of expertise and hence we cannot advise on this)
- Have the necessary Money Transmitter Licenses and/or Cryptocurrency Licenses (where applicable) in the US States from which you are signing up customers and doing business with them.
- Adhere to various state and federal guidelines (including reporting) for anti-money laundering, counter-terrorism financing, PATRIOT Act, Bank Secrecy Act, etc.
- Depending on your flow of funds and transaction specifics, you may require a license in either one state or multiple states.
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