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Games are advanced now that you are able to gain and spend money while playing. This feature allows you to access and possess premium content for your character or avatar. This currency may be earned through achieving certain tasks or quests with corresponding prizes or buy old school runescape account using real money. Being able to own and use virtual currency is an interesting concept, but what compliance should game developers follow regarding game currencies?

The Financial Crimes Enforcement Network or FinCEN is an office under the United States Department of the Treasury which oversees the financial transactions and prevents illegal activities such as local and international money laundering. In 2013, they released a guide stating that the movement of virtual currency or transactions of sending and receiving cryptocurrencies is considered as money transmitting. One familiar type of cryptocurrency is bitcoin. Companies that facilitate these transactions are money transmitters.

There are four kinds of in-game money transmitting:

Merchandise

The developer of the game collaborates with other merchants for users to exchange reward points earned for items. The reward points used in the exchange will be collected by the developer and pays the merchant real currency.  

Marketplace

Similar to a real-life marketplace, users are able to do transactions such as buy, sell, and exchange items in the game. Players accumulate “gold” while playing the game and accomplish achievements and quests in the game. Another in-game currency is “gems” whereas the user buys it with real money.

User-Generated Content

Real-life money is used to purchase virtual currency on the game or “coins”. These coins will be used to purchase items for their character such as weapons, clothes, appearances, equipment, and others depending on the game. The game also allows users to create items and sell to other users with the developer managing the transaction. Users with coins accumulated in-game can exchange the virtual currency for real currency with the developer.

Gifting

“Tickets” in the game can be purchased with real money to be able to view and own special items. These can be gifted to another user for them to purchase premium items.

In all kinds of in-game money transmitting, the developer oversees the transaction between all parties.

Working Around Without a BSA/AML Program

The BSA/AML program is a system that monitors entities that transmits money with the prevention of money laundering and fraud.

Game developers have to modify virtual currency as being only available for in-game purchases and just that. They must clarify certain factors with virtual currency such as the value, legal status, and restrictions in the game’s terms of use.

The developers have to clarify that in-game currencies do not have value like real money. It must also state that these cannot be used outside the game in any form such as cash-outs, exchanged for real goods, or transferred to other users.

Most game developers seek to work around without requiring the said program because it is costly and has a complicated process. Without clarifying the mode of in-game currencies, it could mark the developer and the game as money transmitters.