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Re: [Taler] taler usa thread?

From: Jeff Burdges
Subject: Re: [Taler] taler usa thread?
Date: Sat, 03 Dec 2016 00:44:47 +0100

On Thu, 2016-12-01 at 14:27 -0800, Ryan Stewart wrote:
> Any interest in getting a taler thread started that deals with
> regulatory issues specific to the USA?

In principle yes if anyone knows anything.  :)  We've a big name law
firm doing some analysis.  It might be focused on Europe, but if so it
should still cover the treaties. 

Ideally, we want Taler to be viewed as cash to the extent possible,
meaning the requirements to file suspicious activity reports (SAR) falls
more heavily on the banks with which a Taler exchange interacts, not so
much on the exchange itself, which acts basically as an ATM provider.  

A bank might not know what Taler is though, so one technical the
question is: How do we best explain Taler in an ACH transaction's data?
We want a bank employee who sees lots of transactions to/from Taler USA,
Inc. to instantly know that they should think of those as cash
withdrawals/deposits, but that they are not actually cash in the
conventional sense. 

As for the Taler exchange itself, there is good reason to imagine an
exchange knows its customers well enough to comply with KYC regulations.
If you look at AML stuff for information about filing SARs, then you'll
notice they mostly concern value pasterns, not counter parties. 

I suppose say a BOLT deployment would face more difficulty in complying
with AML rules. 


p.s.  Any anonymity system is vulnerable to patterns, so one tactic is
simply being up front about that so as to scare away as many would-be
money launderers as possible. 

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