Application of Money Services Business regulations to the rental of computer systems for mining virtual currency Summary

Updated 12/27/2021

This tool summarizes FinCEN’s ruling regarding a company that developed a computer system that mines cryptocurrencies. It will rent these computer systems to third parties, allowing the third party to mine virtual currencies. While the third party provides the company information about the mining pool to enter into the system, all of the virtual currency mined by the third party remains with the third party. The following are the key takeaways of the ruling:

1. FinCEN regulations indicate that whether a person is a money transmitter is a matter of facts and circumstances.

2. The rental of computer systems to third parties is not an activity covered by FinCEN regulation.

3. The regulations specifically exempt from “money transmitter” status a person that only provides the delivery, communication, or network data access services used by a money transmitter to supply money transmission services.

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