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#126 - Genuine DeFi as Critical Infrastructure: Paper by Rebecca Rettig, Michael Mosier and Katja Gilman

Law of Code

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Financial Intermediaries and Money Transmission

The chapter explores the various financial intermediaries categorized as financial institutions under the Bank Secrecy Act (BSA). It delves into the exemption provided by FinCEN in 2019 for certain individuals offering support services for money transmission. Additionally, it emphasizes that software development and provision of services are not classified as financial institutions under the BSA.

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