In what circumstances does an investment advisor have to register as a money transmitter?
<p>As far as I understand it, an SEC-registered investment advisor that doesn't hold the client's assets doesn't need extra regulation pertaining to custody. If a robo-advisor like Betterment (although I understand that they're Broker-Dealer-registered) is registered as an RIA and sends client orders straight to the exchange through a broker like Interactive Brokers, do they have to register as a money transmitter? How do the laws change for assets like crypto (sending an order straight to Binance, Coinbase, etc)</p>

<p>A Money Transmitter (MT) is a subset of Money Services Businesses (MSBs) according to the definition of an MSB (<a href="https://www.fincen.gov/money-services-business-definition" rel="nofollow noreferrer">31 §1010.100(ff)</a>). Exempted from inclusion in MSB definition is &quot;a person registered with, and functionally regulated or examined by, the SEC.&quot; As an SEC-registered investment advisor, it sounds like such a robo-advisor would not need to register as a money transmitter business as well.</p>

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