The Financial Crimes Enforcement Network of the US Department of the Treasury has created a guide to the Bank Secrecy Act which requires that businesses engaging with virtual currencies are subject to registration, reporting, recordkeeping and other anti-money laundering requirements. The Guide defines virtual currency as 'a medium of exchange that can operate like currency but does not have all the attributes of ‘real’ currency… including legal tender'. Convertible Virtual Currency (CVC) refers to a type of virtual currency that ‘has an equivalent value as ‘real’ currency, or ‘acts as a substitute for ‘real’ currencies' – like most stablecoins. Under the guidance, whether people are within the regulatory scope depends on their activities. Users who obtain CVCs to purchase goods or services will not fall into the BSA requirements, in contrast to administrators or exchanges of virtual currency that accept, transmit, buy or sell CVCs – qualifying as ‘money service business’.