From: cman@communities.com (Douglas Barnes)
Date: Sat, 7 Oct 95 22:24:46 PDT
To: cypherpunks@toad.com
Subject: Re: cypherpunks digicash bank?
Message-ID: <v02120d02ac9d1e825159@[199.2.22.120]>
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I strongly recommend that anyone considering licensing from Chaum
first read my paper on some interesting aspects of his basic blinding
patent. The paper is at: http://www.communities.com/paper/agnostic.html.

I will be putting up another short paper on anonymous currency
management within the next few days.

Also, I strongly recommend that anyone serious about this not use the
word "bank", and take the time to figure out how to structure the
service as an NBFI (non-banking financial institution) and not a "bank".
Note that NBFIs are still regulated, and you will, at minimum, need to
consult with your state banking regulators as well as the IRS (who
also regulate money transmitters, i.e. issuers of traveller's checks,
moneygrams, etc.) Note that the BSA (Bank _non_ Secrecy Act) does in fact
apply to NBFIs and money transmitters, and you should be sure to educate
yourself as to the implications of this.

I will be covering some aspects of these issues at length in my trip
report on the anti-money-laundering conference I recently attended,
which was a real eye-opener in a number of ways.