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You'd use our platform!

User A sends local currency to User B's fiat account.

User B sends stablecoins (earned via salary, trading, mining, etc.) to User A's digital wallet (that we've created for them).



How do you demonstrate that User B earned their stablecoins via “salary, trading, mining, and etc.”; as opposed to through crime, whether the conventional crypto sort or through subverting currency controls?

What, other than money laundering, would motivate a person who had a supply of such stablecoins to want to supply them to into a market with currency controls? Is the concept there “I make my expat wages in dollars, I want to turn them back into $CURRENCY at the black market rate”?


Does user B need any sort of exchange/money transmitter license?

Do you check the laws for this in each country you are available in?

Do you notify user B of this fact and the potential legal risks?

Do you verify if they have the license?


User B is sending a peer-to-peer transaction, akin to a Zelle or Venmo. In most other countries, these peer-to-peer payments (PIX, UPI, etc.) do billions of transactions per month. And since you're sending your own funds, you're not a money transmitter. If we do work with any larger entities (e.g., an OTC desk, liquidity provider), we'd certainly be cognizant of the relevant licensing.


> And since you're sending your own funds, you're not a money transmitter.

It's MUCH more complicated than that in several countries, particularly the US.


Assuming you get banned, is your plan just "never visit any country where we do business"?


Hahaha we've had this conversation internally a couple of times.

Definitely a few places that we'd probably avoid. But also plenty of others (e.g., Kenya, LatAm, Turkey, etc.) that have been quite friendly and would be fine to visit.


And what are the legal implications for User B.

Because if you are involved in washing illegally earned money in many places that's a criminal act.




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