FinCEN's guidance on crypto business models: are you a money transmitter?

I am hardly a fan of Gerard but this is a well written summary of the guidance.

The only thing I would add to clarify money transmission as "transmitting value that substitutes for currency" is that exchanging funds for goods (normal commerce e.g. buying a coffee with credit card / cash / apple pay / stablecoin) is probably not considered money transmission. But I'm not your lawyer.