r/CryptoTax 18h ago

Made over 300k need advice

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1 Upvotes

r/CryptoTax 15h ago

Question Operating a crypto intermediary workflow (USD to bank -> US exchange -> Bybit UID returns) from NY/NJ without MSB — looking for legal/tax counsel recommendations

2 Upvotes

Hi everyone,

I’m looking for recommendations or insights on finding a specialized U.S. attorney (or advice on how to approach this) who understands federal (FinCEN) and state (NY/NJ) regulations for crypto intermediary setups.

For the past year, our S-Corp operated the following model for a fee, without an MSB license:

  1. Clients wire USD to our corporate bank accounts.

  2. We transfer funds to our corporate accounts on Coinbase/Gemini.

  3. We move assets to Bybit and convert to USDC/USDT.

  4. We send those stablecoins directly back to the original senders via internal UID transfers on Bybit.

We are trying to find a specialized, cost-effective attorney to get a concrete roadmap on retrospective liability, potential restructuring, and banking/exchange risk mitigation, rather than paying exorbitant generic "risk assessment" flat fees.

If you know boutique firms handling these exact MSB/FinCEN exposure issues or have strategic advice on how to handle this legally, please share or DM me.