I don't think this is a money transmitter business.
It's a regular trading merchant who buys and sells goods at a spread. Just make sure the contracts reflect this.
I was thinking of doing this in Finland, but then you'd be a money transmitter and probably have to do KYC, which trashes the UX and defeats the purpose.
Setting up BTCPay Server or https://opennode.com for my favorite online stores might be a better way to make them accept bitcoin. Help them with bitcoin storage, exchange and accounting. The EU kindly doesn't yet require KYC from them.
What would be even more rad? Crawl online stores onto Shopstr, let users send orders that are paid in Cashu. Notify merchant of pending orders and let them redeem the nuts. User can reclaim the payment if merchant did not respond.
Discussion
It is in New York. You can buy something with Bitcoin, and accept Bitcoin as payment, but you can't facilitate the exchange of Bitcoin into something else on behalf of someone without a license:
200.3 License.
(a) License required.
No person shall, without a license obtained from the superintendent as provided in this Part, engage in any virtual currency business activity. Licensees are not authorized to exercise fiduciary powers, as defined under section 100 of the Banking Law.
(b) Unlicensed agents prohibited.
Each licensee is prohibited from conducting any virtual currency business activity through an agent or agency arrangement when the agent is not a licensee.
(c) Exemption from licensing requirements.
The following persons are exempt from the licensing requirements otherwise applicable under this Part:
(1) persons that are chartered under the New York Banking Law and are approved by the superintendent to engage in virtual currency business activity; and
(2) merchants and consumers that utilize virtual currency solely for the purchase or sale of goods or services or for investment purposes.
23 CRR-NY 200.3
Current through June 30, 2022