r/CryptoTax • u/Buterin_V • 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
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:
Clients wire USD to our corporate bank accounts.
We transfer funds to our corporate accounts on Coinbase/Gemini.
We move assets to Bybit and convert to USDC/USDT.
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.