Regulatory History
Abstract: Regulatory action against digital currency
systems started quietly in Australia in 2004. In 2005, e-gold
was raided but no charges were filed. In 2007, GoldAge, one
of the original exchange agents, was closed and prosecuted.
Also in 2007, the e-gold operators were indicted on multiple
felony charges and the assets of about a dozen exchange
agents in America were seized. Similar actions to separate
digital currency businesses from US banking faculties can
be seen today in the operation of US Bitcoin businesses.
Mullan, Carl P. The Digital Currency Challenge:
Shaping Online Payment Systems through US Financial
Regulations. New York: Palgrave Macmillan, 2014.
DOI: 10.1057/9781137382559.0008.
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The question of regulating digital currency at the federal level and
requiring state licensing dates back more than ten years. In 2002, early
digital currency operators were unaware if their companies required
licensing. Mr. James Fayed, the operator of e-bullion.com and owner
of Gold Finger Coin & Bullion, asked his corporate attorney to inquire
with the State of California requesting clarification if a money transmitting
license was required for the e-bullion.com business. The response
from state officials at that time was negative. In 2002, the attorney for
e-bullion.com was informed by the state that its business did not require
a California Money Transmitting License. “They are not eligible for a
money transmitter license because their business model was not taking cash
from person A and delivering cash to person B.”1
 With the popularity of
e-gold on the rise around the world, the governments of other countries
such as India were also taking notice of digital currency. In October
2002, the Reserve Bank of India (RBI) banned digital gold as a payment
channel in that country. Specific digital gold companies mentioned by
the government and included in this ban were e-gold and GoldMoney.2
In September 2004, several Australian independent digital currency
exchanges ceased operation due to the strict application of Financial
Services Licensing regulations in that country. Digital gold currency
exchangers that were forced to close by the Australian Securities and
Investments Commission (ASIC) included: goldex.net, sydneygoldsales.
com, and ozzigold.com. While digital currency systems and these
exchange operations in Australia had not yet been legally defined by
government regulators, the ASIC believed digital currency products
could be defined as non-cash payment systems. In Australia, people who
deal in these products with Australian consumers are required to hold
an Australian financial services license (AFSL).3
In 2004, in what was a friendly action by the Australian government,
there were no arrests and no seizures. The local Australian companies
all cooperated with ASIC throughout the investigation. Each exchange
operation voluntarily withdrew company websites and closed businesses.
The independent exchange agents operating in Australia simply moved
to other jurisdictions and continued business under a different name or
sold the business to associates in other countries. Australia’s new regulations
had no long-term effect on e-gold liquidity or the digital currency
industry. Since the online digital currency marketplace was global,
Australian digital currency consumers simply continued transacting
business through other countries. For easy operation, some Australian 
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users even opened New Zealand-based bank accounts and transacted
their digital currency business through New Zealand.
The events which unfolded following this brief government response
in Australia, became a reactionary model for future digital currency
regulatory events. This has become a well-recognized trend in digital
currency. Due to the global nature of Internet digital currency, when one
environment, jurisdiction, or network becomes too regulated businesses
seeking to maintain their profitable enterprises, especially bad actors,
will simply change jurisdictions or platforms. This friendly action by the
Australian government in 2004 was the only large regulatory event to
take place prior to US law enforcement action against e-gold.
On the evening of December 19, 2005, agents with the Federal Bureau
of Investigation and Secret Service raided the Melbourne, Florida, office
of e-gold’s parent company, Gold & Silver Reserve Inc., and the local
residence of founder, Dr. Douglas Jackson. No arrests were made at that
time. That evening agents seized e-gold records, financial records, and
volumes of data. The information, seized by the Secret Service, pertained
to e-gold accounts, transaction information, electronic records, and other
documents. Agent James Glendinning from the Secret Service’s Orlando
office stated that “the 2005 raid was a spinoff of a 2004 international
crackdown on Internet identity thieves who had used e-gold to receive
payments.”4
 As a direct result of the 2005 seizure, a court order froze all
the US bank accounts of e-gold’s parent company. The December 2005
raid temporarily crippled the e-gold operation due to its loss of access to
US bank accounts.
A similar situation is now occurring with Bitcoin. Since July 2011,
when the new MSB rule began to be implemented, US commercial banks
have withdrawn from digital currency activity. Banks, fearing regulatory
action and possible association with the illegal proceeds of crime, have
been turning away from companies dealing in Bitcoin. With the US
government’s seizure of Wells Fargo and Dwolla accounts, Mt. Gox, the
largest Bitcoin exchange, has been unable to create any additional US
banking faculties.
 In May 2013, the Department of Homeland Security issued a
seizure warrant to US payment processor Dwolla for the money in
Mt. Gox’s Dwolla account (Mutum Sigillum LLC, a US subsidiary
of Tokyo-based Mt. Gox). Mt. Gox is no longer processing any
funds through US banks. The company had failed to register in the 
Regulatory History 
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United States as a money transmitter and it appears that Mt. Gox
had allegedly been in violation of US banking regulations for about
18 months.5
 In July 2013, California-based Bank of the West began requesting
information regarding the application of money service business
regulations to the precious metals business of Amagi Metals
(Amagi, Inc.). While it was clear that Amagi Metals only accepted
Bitcoin as a method of payment, the bank closed their business
account citing that they believed it was a risk to do business
because of Bitcoin. Wells Fargo also rejected their business citing
that even “holding” virtual currency as a business prevents the
bank from offering them a new account.6
 In April 2013, New York-based Bitfloor closed down their operation
citing that the company’s US bank account had been involuntarily
closed.7
 Forbes Magazine reported in November of 2013 that BitInstant, a
New York Bitcoin trading company, had been denied accounts at
NY Chase, Wells Fargo, Citibank, and US Bank.8
 In July 2013, Jay Shore of Coinabul stated that both US Bank and
Chase had informed him they were closing the company’s bank
account.9
 Tradehill Inc., a California Bitcoin exchange agent, suspended
trading in August 2013 citing unspecified banking and regulatory
reasons from its bank Internet Archive Federal Credit Union
(IAFCU). Jered Kenna, CEO of Tradehill, says they have now been
turned down by over one hundred banks.10
 In late August of 2013, Jordan Modell, the CEO of the Internet
Archive Federal Credit Union, stated that certain operational and
regulatory issues had come to light and that the company would
be unable to offer any Bitcoin-denominated accounts until further
clarity was available.11
 Presently, the Tradehill website states that the company has
registered with FinCEN and is “actively engaging with banks and
regulators to continue development of future business products and
practices.”12
 In the second quarter of 2013, Bitbox, a Michigan Bitcoin exchange,
had its bank account at Comerica closed for no reason. Company
CEO Kinnard Hockenhull then moved to IAFCU only to encounter
the same problems months later.
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 Bitspend, a bitcoin-based company which allows visitors to buy
items on non-Bitcoin websites and pay in BTC, closed down
indefinitely. The former operator of Bitspend stated that Chase
bank decided that as a Bitcoin-based business it was too high risk
for the bank. Bitspend’s accounts were frozen and closed.13
Today, US banks have no incentive to work with digital currency
exchange operations and traditional MSBs are having a difficult time
obtaining a US bank account. Based on the history of e-gold and other
exchange agent operations in the United States, it is likely that this trend
in the US market will continue with decentralized currency operations
related to Bitcoin.
In an interview with American Banker Magazine in May 2013, Jennifer
Shasky Calvery, the director of FinCEN, stated that she did not believe it
was MSB regulations that had “caused banks to de-risk themselves from
operating in the MSB arena.”14 However, she mentioned that regulatory
action and criminal enforcement against the biggest money launderer in
US history, a reference to the digital currency company Liberty Reserve,
could lead some banks to be overly aggressive in moving away from all
digital currency business. Over the long term, digital currency experts
believe that the MSB rule may have a negative effect on legitimate US
digital currency companies and even those foreign-located Bitcoin companies
seeking to do business in the United States.15 These actions are not
new. Since the 2005 e-gold raid, there has been a very well-recognized
pattern of isolating digital currency companies from access to US banks.
This strategy works well to cripple or close any digital currency business
operating from the United States. A similar situation occurred with digital
currency during 2005–2008. Citing the risks associated with “digital
currency,” the US banks were not handling accounts and doing business
for digital currency companies. This included merchant card processing.
In years past, when banks began turning down or closing digital currency
accounts, it was generally recognized as a sign that the US market
was fading. This same lack of access to US banks helped to close down
digital gold company Crowne Gold in July of 2008.
Today, the federal government and law enforcement agencies need to
take a more sensitive approach to the future of Bitcoin in America. US
regulators need to consider a “partnership” with decentralized currency
developers and new Bitcoin businesses. The reality of all global digital
currency, both past and future, is that users and merchants will either 
Regulatory History 
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thrive in a regulated legitimate US market or operate underground and
offshore. US banks can either fight the Bitcoin money service businesses,
with a tired e-gold strategy, or engage the industry in healthy dialogue
developing strategies that will cause the United States to become a
world leader in digital currency innovation. Long-term action should be
taken today in order to foster an environment where MSBs have access
to banking and financial services in the future. If US banks don’t start
cooperating with money transmitting Bitcoin-related businesses, all
those potential US Bitcoin transactions will find a home offshore. If the
business is pushed offshore, the United States will lose out on the creative
new products from a global market and also any second stage innovation.
Instead of becoming US partners in the fight to detect potential
Bitcoin money-laundering and terror financing, the government’s inaction
could result in much higher risks to consumers and an underground
marketplace that hinders law enforcement efforts to track illicit financial
transactions. Partnering with banks and new Bitcoin MSBs at this early
stage increases the probability of regulatory compliance and taxation
within US borders.
American merchants require US dollars. Online American merchants
accomplish everyday financial tasks through US banks. Whether the
operation is e-gold, Bitcoin, or any other digital currency, if everyday
access to US banks is blocked for a digital currency business, it is very
possible that a majority of US merchants and customers will avoid using
that digital currency product, since liquidity is one of the three driving
forces behind all successful digital currency systems. If the process of
exchanging digital currency into national currency is slowed or stopped,
US customers will be averse to using that financial product.
Additionally, the 2005 e-gold search warrant had permitted open
government access to all e-gold accounts. Prosecutors in the case caused
the Grand Jury to order complete dumps of the entire e-gold database on
at least three separate occasions during the investigation. This exposed
the financial records for tens of thousands of e-gold users never accused
of any crime and never involved in any criminal activity. This turned
out to be a particularly noteworthy act by government prosecutors.
Under the Right to Financial Privacy Act, 12 USC §§ 3401–342, customers
of digital currency companies should be afforded the same rights
as bank customers. The Right to Financial Privacy Act of 1978 protects
the confidentiality of personal financial records by creating a statutory
Fourth Amendment protection for bank records. The definition of 
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financial institution was expanded in July 2002 to include money service
businesses. Only specific e-gold accounts that had been identified as
involved in criminal activity should have been accessed. The RFPA states
that “no Government authority may have access to or obtain copies of,
or the information contained in the financial records of any customer
from a financial institution unless the financial records are reasonably
described.”
The statues requires that the requesting federal government agency must
give the customer advance notice of the requested disclosure from the
financial institution, thus giving the customer opportunity to challenge the
government’s access to the records before the disclosure takes place.16
No charges were filed against e-gold in 2005 or 2006 and the digital currency
business continued to expand around the world.
In July of 2006, GoldAge, a very popular independent digital currency
exchange agent in New York, was closed and the owners arrested for
allegedly violating Article 13-B of New York State Banking Law. This digital
currency operation was one of the first to be charged with operating
a money transmitting business without a state license (New York). It is a
class “E” felony to engage in the business of transmitting money without
a license if one knowingly receives $250,000 or more for transmission
within a period of one year or less, $25,000 or more in a 30-day period
or less, and $10,000 or more in a single transaction. While the indictment
included only the illegal money transmitting activity from January
2006 through June 30, 2006, GoldAge had been one of the first exchange
agent operations in the United States and had originally opened, under
different owners, in 1999. In July 2006, the company’s bank accounts
were seized and never returned. The operators Arthur Budovsky and
Vladimir Kats lost an estimated several million in cash deposits and
volumes of personal client information and transaction details. The case
concluded with each party being found guilty in the State of New York
and sentenced to five years in prison. However, both sentences were
reduced to probation.
In a separate action by the Federal government, seven years later, in
May 2013, both Arthur Budovsky and Vladimir Kats were again arrested
along with others and charged by US Federal prosecutors under the USA
Patriot Act. After a lengthy investigation by authorities across 17 countries,
the government charged Budovsky, Kats, and others with money
laundering and operating an unlicensed financial transaction company 
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from Costa Rica. In what is alleged to be the largest money laundering
prosecution in US history, Liberty Reserve is said to have been used to
allegedly launder more than $6 billion in criminal proceeds during its
history.
For 16 months starting with the December 2005 e-gold raid through
April 2007, no criminal charges had been filed against e-gold or its
principles. During that time there were no civil actions or cases from
any other US regulatory agency. However, in April of 2007, US government
prosecutors presented evidence to a Grand Jury and indictments
were returned on the e-gold operation. On Friday, April 27, 2007, the
US attorney for the District of Columbia made public a four-count
indictment which charged e-gold Ltd., Gold & Silver Reserve Inc., and
owners Dr. Douglas L. Jackson, 50, of Satellite Beach; his brother Reid
A. Jackson, 44, of Melbourne; and Barry K. Downey, 47, of Woodbine,
Md., with four crimes: one count of conspiracy to launder monetary
instruments, one count of conspiracy to operate an unlicensed
money transmitting business, one count of operating an unlicensed
money transmitting—business under federal law—and one count
of money transmission without a license under DC law. Of the four
counts in the indictment, three related directly to operating without
the proper money transmitting license. At that same time, in separate
criminal actions, the government issued 24 seizure warrants on at least
58 large e-gold accounts. Alleging the e-gold contents included property
involved in money laundering and the operation of an unlicensed
money transmitting business, the government forced G&SR to seize
and liquidate the contents of the accounts. This included the accounts
of e-gold’s primary exchange agent OmniPay. US located independent
digital currency exchange agents and businesses transacting large
amounts of e-gold were the clear target of these seizures. Large US and
foreign exchange agents including The Bullion Exchange, AnyGoldNow,
IceGold, GitGold, The Denver Gold Exchange, GoldPouch Express,
and even the alternative payment system “1MDC,” which was backed
by e-gold, all lost substantial funds in the government action. The
gold bullion represented by all of the accounts was sold and the funds
were delivered to the government in the seizure. These independent
e-gold exchange agents had been buying and selling e-gold. At the
time, these companies were operating as independent exchange agents
for several digital currencies including e-gold. However, the seizure of
these exchange agent e-gold accounts occurred under the Racketeer 
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Influenced and Corrupt Organizations (RICO) statutes signaling the
government’s interest in pursuing third-party e-gold exchange agents.
The 1961 Racketeering Act, also known as the RICO Act, is a tool of law
enforcement which originally emerged to combat organized crime.17
Due to the arrests and seizures, e-gold’s bullion reserves dropped from
112,188 ounces (3,491.0 kilograms) in April 2007 to 84,856 ounces (2,461.2
kilograms) by June 2007. This was a drop of over 1,000 kilograms of gold
bullion.
While this coordinated legal action closed several of the industry’s
largest US exchange agents, including the primary dealer OmniPay, at
that time there were more than 120 active independent e-gold exchange
agents worldwide and the global e-gold business continued operating.
While exchange transactions decreased and merchant activity was
reduced, e-gold’s daily business did not stop and the operation remained
in existence. Seized funds from the 58 e-gold accounts and bank accounts
of G&SR were never returned.
The criminal case against e-gold was brought under Title 18 USC section
1960. The e-gold defendants made a determined argument that the
business should not be subject to current Treasury regulations, however,
the judge rejected the argument. In February 2008, e-gold had filed a
motion to dismiss the case on the grounds that the company’s business
did not fit the legal definition of a money transmitter. In May of 2008,
Judge Rosemary M. Collyer held that:
 “money transmitting business” in governing criminal statute was
not restricted to business that handled cash;
 defendants operated “money transmitting business” within
meaning of Money and Finance Code provision mandating
registration of such businesses;
 criminal stature was not void for vagueness18;
From that date forward, the judge’s opinion made it very clear that anything
of value, not just cash or national currency, could be transmitted
online and was regulated under the existing law.
As part of an agreement, in July 2008, the company and its three directors
pleaded guilty. In November, Gold & Silver Reserve CEO Douglas
Jackson was sentenced to 300 hours of community service, a $200 fine,
and three years of supervision, including six months of electronically
monitored home detention. Reid Jackson, Douglas Jackson’s brother,
and e-Gold director Barry Downey were each sentenced to three years 
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of probation, 300 hours of community service, and ordered to pay a
$2,500 fine and a $100 assessment fee each.19 The plea agreement did not
close down the e-gold business. The business was permitted to continue
operating with the following significant restraints:
 registration with FinCEN;
 all required state money transmitter licensing;
 creation and implementation of an anti-money laundering program
which includes rigorous customer verification;
 suspicious activity reporting (SAR);
 blocking of accounts for specially designated nationals (SDNs) and/
or politically exposed people (PEP);
 employee AML training;
 independent audits; and
 other safeguards to the system.
Unfortunately, as convicted felons, none of the former operators of
e-gold could ever be licensed, at any future time, for this type of work in
the US financial industry. The legal importance of this case should not
be understated. Judge Rosemary Collier’s 19-page Memorandum of Law
in Support of Defendants’ Motion to Dismiss Counts Two, Three and
Four of the Indictment changed the way digital currency was recognized
in America. For almost a decade e-gold had been operating unlicensed
using the justification the company never handled cash transactions and
was not required to be licensed. The court found this to be untrue and all
other digital currency businesses, from that date forward, were required
to be licensed at a federal and state level (several US states do not require
money transmitting licenses). This included digital currency providers,
operators, and all exchange agents. The e-gold case in 2008 was a landmark
case for digital currency. The ruling said that if the digital currency
is backed by gold, national currency, or by nothing and called a “decentralized
virtual currency,” that convertible digital value is recognized
by the US government, and those companies engaged in transmitting
value online are financial services which require proper licensing. This
is painfully obvious in the case Mt. Gox. Mark Karpeles, founder and
owner of Mt. Gox, could be facing charges as federal law enforcement
agents allege Mutum Sigillum, LLC engaged in a money transmitting
business although it was not registered with FinCEN and acted as an
unlicensed money service business in violation of 18 USC Section 1960.
The earlier case of GoldAge, in 2006, was another independent exchange 
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agent prosecuted for failing to obtain proper licensing in New York State.
The prosecution in 2008 of Michael Comer for operating Intgold digital
currency without a money transmitter license is another prime example.
There have been several prominent US cases in which digital currency
companies and their operators have been charged with operating an
unlicensed money transmitting business. Here is the short list of related
cases (partial list of charges per case for each individual):
 Dr. Douglas Jackson, Reid Jackson, Barry Downey (e-gold) Count:
3 18:1960 and 2; Monetary Laundering; Prohibition of Unlicensed
Money Transmitting Business and Aiding and Abetting.
 James Michael Fayed and Goldfinger Coin & Bullion, Inc.
(e-bullion), 2–08-cr-00224-PSG-1 USA v. Fayed et al, Count: 1 18
USC § 1960 Operating an unlicensed money transmitting business
02/26/2008.
 Michael Comer (Intgold) 3–08ncr-00085-N All Defendants USA
v. Comer 03/28/2008 Count: 1 18 USC § 1960 (a) and (b) (1) (B)
Operating an unlicensed money transmitting business.
 Vladamir Kats (GoldAge), Arthur Budovsky (GoldAge) [State of
New York] Count: 2 18:371.F Conspiracy to operate an unlicensed
money transmitting business, Count: 3 18:1960.F Monetary
laundering (Operating an unlicensed money transmitting
business).
 Vladamir Kats et al (Liberty Reserve S.A.), 1:13-cr-00368-DLC USA
v. Kats et al Date filed: 05/20/2013[Costa Rica], Count: 2 18:371.F
Conspiracy to operate an unlicensed money transmitting business,
Count: 3 18:1960.F Monetary Laundering (Operation of unlicensed
money transmitting business), With respect to Count 2, the Liberty
Reserve indictment specifically references the new July 2011 MSB
Rule and its application to foreign-based businesses.
Since 2008, there has been no question that US regulations require
digital currency businesses to be properly licensed. In fact, the original
e-gold conviction was obtained before the first Bitcoin ever circulated.
Despite the fact that both e-gold and e-bullion had, at separate times,
requested information from the government on whether or not the
companies were required to obtain the proper government licensing,
e-bullion in 2002 and e-gold in 2006, both companies were eventually
charged with crimes relating to operating without a money transmitter
license.
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Notes
 K. Griffith (kengriffith@gmail.com), e-bullion follow up, [email] message to
C. Mullan (carl@pdxcurrency.org), November 19, 2013.
 Rediff.com, 2002. rediff.com: RBI Bans Gold Money as Payment Channel.
[online] Available at: http://www.rediff.com/money/2002/oct/22gold.htm
(accessed: December 13, 2013).
 Asic.gov.au, 2004. Australian Securities and Investments Commission - 04–366
ASIC Acts to Shut Down Electronic Currency Trading Websites. [online] Available
at: http://www.asic.gov.au/asic/asic.nsf/byheadline/04–366+ASIC+acts+to
+shut+down+electronic+currency+trading+websites (accessed: December
13, 2013).
 FLORIDA TODAY, 2002. FLORIDA TODAY Breaking News Section.
[online] Available at: http://www.floridatoday.com/apps/pbcs.dll/
article?AID=/20070428/BREAKINGNEWS/70428010/1086&nclick_check=1
(accessed: December 13, 2013).
 V. Buterin, 2013. MtGox’s Dwolla Account Seized for Unlicensed Money
Transmission. [online] Available at: http://bitcoinmagazine.com/4641/mtgoxsdwolla-account-seized/
(accessed: November 18, 2013).
 Reddit.com, 2013. Bank of the West Is Shutting Down Our Bank Account because
We Accept Bitcoins: Bitcoin. [online] Available at: http://www.reddit.com/r/
Bitcoin/comments/1inixa/bank_of_the_west_is_shutting_down_our_bank/
(accessed: December 13, 2013).
 K. Hill, 2013. Bitcoin Companies and Entrepreneurs Can’t Get Bank Accounts.
[online] Available at: http://www.forbes.com/sites/kashmirhill/2013/11/15/
bitcoin-companies-and-entrepreneurs-cant-get-bank-accounts (accessed:
December 13, 2013).
 Ibid.
 Ibid.
 E. Spaven, 2013. Tradehill Suspends Trading Due to “Operational and Regulatory
Issues.” [online] Available at: http://www.coindesk.com/tradehill-haltstrading-due-to-iafcu-operational-and-regulatory-issues/
(accessed:
December 13, 2013).
 J. Modell, 2013. Rocky Road Is Still One of My Favorite Flavors « Internet Credit
Union. [online] Available at: https://internetcreditunion.org/uncategorized/
rocky-road-is-still-one-of-my-favorite-flavors/ (accessed: December 13,
2013).
 Finextra.com, 2013. Finextra: Tradehill Suspends Bitcoin Trading in Face of
Regulatory Heat. [online] Available at: http://www.finextra.com/News/
FullStory.aspx?newsitemid=25165 (accessed: December 13, 2013).
 Reddit.com, 2013. [Update/News] Why We Have Been Slow and Taking Longer
Than Usual to Process Orders. Hint, Banks Don’t Like Bitcoins: BitSpend. 
 The Digital Currency Challenge
DOI: 10.1057/9781137382559.0008
[online] Available at: http://www.reddit.com/r/BitSpend/comments/1go95b/
updatenews_why_we_have_been_slow_and_taking/ (accessed: December
13, 2013).
 R. Blackwell, 2013. Fincen Chief Q&A: What We Expect from Digital Currency
Firms. [online] Available at: http://www.americanbanker.com/issues/178_104/
fincen-chief-q-and-a-what-we-expect-from-digital-currency-firms-
1059485–1.html (accessed: December 16, 2013).
 Ibid.
 Epic.org, 2013. EPIC—The Right to Financial Privacy Act. [online] Available at:
http://epic.org/privacy/rfpa/ (accessed: December 13, 2013).
 United States of America v. All Property in/underlying e-gold Account Number, 25
Cases 1:07-cv-01322-RMC thru 1:07-cv-01345-RMC (2007).
 Memorandum of Law in Support of Defendants’ Motion to Dismiss Counts
Two, Three and Four of the Indictment at 13–14, United States v. E-gold Ltd.,
550 F. Supp. 82 (D.D.C. Feb. 11, 2008) (No. 07–109).
 Department of Justice, 2008. Digital Currency Business E-Gold Pleads Guilty
to Money Laundering and Illegal Money Transmitting Charges. [press release]
Monday, July 21, 2008.