Re: Opensim-users Digest, Vol 9, Issue 13

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Re: Opensim-users Digest, Vol 9, Issue 13

Erik Bainbridge (Apollo Manga)
Re: Opensim-users Digest, Vol 9, Issue 13 You're right, Virwox (OMC) is located in Austria.

My impression is that both Virwox and Podex feel they are not subject to FinCEN because they are not based in the US.  However I've asked FinCEN and was told that any financial company needs to register if they have any US customers, regardless where the company is based.

Erik Gordon Bainbridge Author, virtual worlds builder/reporter
www.VirtualMarin.com
www.ErikBainbridge.com
www.examiner.com/second-life-in-national/apollo-manga
www.WarriorBrothers.com
www.MountainBikeRoots.com

>
> IANAL but that seems to be the situation in the US, if you allow
> people to cash out. I haven't heard of any actual enforcement, but the
> theoretical penalties are quite steep. This is the key opinion from
> FinCen, in addition to which the individual states have an amazing
> rats nest of requirements that aren't discussed here:
> http://fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html
>
> Another interesting question arising from this is how much you have to
> worry about this stuff if you're not based in the US but some of your
> customers are.
>
> IIUC OMC is based in the EU (Austria?) - I'd be interested to hear if
> anyone knows what their regulatory status is.

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