Seeking legal advice for smartcoin/colored coin issuers


#1

I propose that this thread be a place where those familiar with laws governing the financial sector (regardless of the country) could offer advise.

Terms:
Smartcoins (SMC) is a bitcoin which is traceable to a certain address.
USDcoin is a smartcoin which the issuer pegged to the dollar.

Here is the context in which legal advice is sought:

A business wants to accept BTC from customers, then exchange the BTC for USD and issue USDcoins to the customer. There exists an ennormous amount of trust between the business and the customers - the customers trust 100% that the business will be honest and not run away with their money. The customers agree that for the first year after the business issues USDcoins, the customers will not be able to redeem USDcoins back to fiat via the business.

My question is:

  1. Because the business receives BTC as deposits and is not planning to process fiat withdrawals, are there countries where such a business is not required to comply with burdensome AML/KYC procedures?
  2. Because the business exchanges BTC to USDcoins (which are in fact just another BTC), are there countries where the business doesn’t have to register as an emitter of shares.

Any advice regarding the legal side is welcome. Please refrain from discussing the viability of the business model - it is simplified for the purposes of this discussion.