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Sarah Shtylman
@shodyesq
FinCEN told the DOJ they didn’t think samouri wallet was a money transmitter.
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Sarah Shtylman
@shodyesq
I’ve seen lot of attention and indignation over the fact this was FinCEN’s position but the DOJ prosecuted anyway. But leaving aside my own pov and the timing of this particular communication, this seems like exactly the type of thing we can and should expect in a Loper Bright / post Chevron world.
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