fincen.gov (Financial Crimes Enforcement Network) issued FIN-2013-G001.
A user of virtual currency is not an MSB* under FinCEN’s regulations and therefore is not subject to MSB registration, reporting, and recordkeeping regulations. However, an administrator or exchanger is an MSB under FinCEN’s regulations, specifically, a money transmitter, unless a limitation to or exemption from the definition applies to the person
*MSB = money services businesses.