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Is it required to register our company with FinCen? Despite not touching the funds, we have no intention of opening an account in the US, our tax address is in Ecuador.

As you are not touching the funds, this does not make you a money services business and hence, registration with FinCEN is not required (this is our opinion, however, IANAL: I am not a lawyer, so please see professional legal advice). Your payout partner (may, and we are not experts in this opinion) may be required to register with FinCEN, but under the general RAAS offering, FinCEN registration is not required.




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