What regulations would a peer to peer money transfer platform face (TransferWise model but without an intermediary)? The platform does not touch money. It allows peers to find matching, opposing transactions and conduct the money exchange themselves.

If a State or Federal regulator cannot find an exact way to pin this marketplace down, then they go after intent. Barring the problem the marketplace will face with respect to trust, etc. let us look at the intent. The intent will clearly how that without the market place, the transaction cannot take place. How […]

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Do I need a money transmitter license if I receive money on behalf of a person in another country (e.g., Ghana)? I make a pay out to this person in Ghana at the end of every month. This arrangement prevents excessive microtransaction fees.

This makes you an intermediary, when you cited on behalf of a person, implies you are neither the owner of the transaction, nor the recipient and hence this makes you an intermediary, and where ever you go, in most countries this would classify you as a money transfer business and thus require you to get licensed.

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