Our E Wallet

[gofish2d]

Hi all, been awhile since I've been on here so I hope I'm posting this in the right place.

We created an E-wallet to primarily be used by our customers. My concern is that most of our users will be located in the USA. USA states each license these wallets and that adds up to a lot of time and money. This will be used by us so I think it's considered a closed wallet and that may not require 50 licenses (one from each state). However, the card processing companies (so customers can deposit into their wallets with us) seem to prefer licensing.

Can I get some recommendations from you guys on what countries are best for this type of licensing (believe it would be EMI license but not positive)?

 

[Sols]

What does your e-wallet do exactly? Who is it for?

As a customer, what do I get by opening an account with your e-wallet?

 

[gofish2d]

What does your e-wallet do exactly? Who is it for?

As a customer, what do I get by opening an account with your e-wallet?

We have sweepstakes sites at gofish.today and treasurerewards.club. Most of these users use Cashapp. We've had a lot of problems with them and want players to utilize this new wallet. It will be used for players to send us money (purchases) from their wallet account to ours. And for us to send winnings to their wallet accounts with our wallet.

 

[gofish2d]

Anyone?

 

[reallyawesome1111]

I am not a lawyer but if you are just sending users their own money through the same medium they sent it to you I don't think it is money transmission. If you were to allow them to deposit CashApp and withdraw to Paypal for instance then maybe you could have a problem. Usually unlicensed money transmitter violations would be when users are sending money to other users.

Based on your site though it looks like you are doing gambling too? You would need a license to offer gambling in the states where it's allowed though based on the Costa Rica license at the bottom I suspect you don't plan on doing that. Casinos have to register with FINCEN and file suspicious activity reports and stuff like that. I hope you have a good plan for payment processing if you plan on taking Americans as customers. Places like Bovada regularly cycle through front companies because they get caught by payment processors or Paypal which is why they promote crypto so much now.

 

[JohnLocke]

Best advise would be to consult a lawyer who can help you in your situation locally. If you are violating any money laundering laws or similar you get in deep troubles.