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For example, you charge a fee in the virtual currency itself (or some other virtual currency) for exchanging it in some way that does not involve legal tender of any jurisdiction.

What would you be exchanging it for, then?

All the Treasury is trying to regulate is the exchange of dollar-denominated wealth into another currency, whether actual (fiat currency of some jurisdiction) or virtual. They don't care about transactions that don't involve dollars on one side (at least not as addressed by this letter).



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