Crypto Stop, LLC d/b/a Neutral ATM
Neutral ATM takes compliance seriously. Neutral operates physical Bitcoin ATM kiosks in Florida and Texas
and conducts Bitcoin transactions directly with customers.
FinCEN Registration
Legal Entity: Crypto Stop, LLC
DBA: Neutral ATM
FinCEN MSB Registration No.: 31000171643270
Neutral is registered with the U.S. Department of the Treasury's Financial Crimes Enforcement Network
(FinCEN) as a Money Services Business.
Compliance & Regulatory Information
Our Transaction Structure
- Neutral's Bitcoin ATM transactions are conducted directly between the customer and Neutral. Neutral:
- Acts as the principal counterparty to customer transactions
- Uses its own Bitcoin treasury to execute Bitcoin transactions
- Uses its own fiat treasury for applicable transactions
- Does not act as an intermediary between customers and third parties
- Does not maintain Bitcoin balances for customers
- Does not maintain fiat balances for customers
- Does not custody cryptocurrency or fiat funds for customers
Florida
Neutral operates Bitcoin ATMs in Florida under a direct principal-to-customer transaction model. Neutral's legal analysis concludes that its specific Bitcoin ATM activities do not require a Florida money transmitter license because Neutral purchases and sells Bitcoin from its own treasury and does not act as an intermediary. The legal analysis relies, among other things, on Florida Statute §560.102(23) and the Florida Office of Financial Regulation's declaratory determination concerning Emerging Assets, LLC d/b/a Bit Chase. Based on that analysis, Neutral does not require a Florida money transmitter license for the Bitcoin ATM activities described in the legal opinion
Texas
Neutral operates Bitcoin ATMs in Texas using the same direct principal-to-customer model. Neutral's legal analysis relies on Texas Department of Banking Supervisory Memorandum 1037. The memorandum describes circumstances in which a Bitcoin ATM facilitates a sale or purchase of Bitcoin directly between the machine operator and the customer, without a third-party intermediary. Under the circumstances described in the memorandum, such activity does not constitute money transmission. Based on that analysis, Neutral does not require a Texas money transmitter license for the Bitcoin ATM activities described in the legal opinion.
Customer Verification & Monitoring
Neutral maintains compliance procedures applicable to its Bitcoin ATM operations. Depending on the transaction, customers may be required to provide identification or other information. Transactions may be subject to:
- Customer identification requirements
- Transaction limits
- Transaction monitoring
- Anti-money-laundering controls
- Sanctions screening
- Recordkeeping requirements
- Other applicable regulatory requirements
Regulatory Disclaimer
Neutral's regulatory status described on this website is based on the specific business model and transaction structure described above. Applicable laws and regulations may change, and requirements may differ depending on the nature, structure, and location of a transaction. Nothing on this website should be interpreted as legal advice.