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I run FaceCash. I would advise talking to a lawyer. (I am not a lawyer.)

I would also advise, to anyone who can make it, going to Sacramento on March 11:

I've talked with lawyers! I don't advise running an exchange anywhere near the United States. (But yes, I'm not a lawyer either.)

If I didn't have jury duty I would be there. I hope you can shed some light on these guys. Can I expect another post with updates? :)