An article from Wilson Sonsini Goodrich and Rosati on 28 May is concerned with gaming companies inadvertently finding themselves subject to these AML laws in the US (with attendant registration, recordkeeping, and other requirements) by offering gamers the ability to purchase in-game currencies, digital goods, electronic gift cards, and similar products. It advises that, before offering a product like in-game currencies, a gaming company should, at a minimum,5 determine whether, by offering that product, it qualifies as one of the 3 types of money services businesses which the article identifies. It also cautions that, while many gaming companies already limit the transferability and tradability of their in-game currencies, digital goods, and similar products in their online terms and conditions or end-user licence agreements, these limitations have not stopped secondary marketplaces for in-game currencies and digital goods from popping up.
https://www.jdsupra.com/legalnews/how-gaming-companies-can-become-67064
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