Here, I think, there is a better argument to be made in that the definition of money transmitter business requires a “party” to be sending and/or receiving currency. If you dig into what that actually means, we’re likely going to end up with a definition like this, from the Code of Federal Regulations: “an individual, a corporation, a partnership, a trust or estate, a joint stock company, an association, a syndicate, joint venture, or other unincorporated organization or group, an Indian Tribe (as that term is defined in the Indian Gaming Regulatory Act), and all entities cognizable as legal personalities.”
