Last week, FinCEN issued two administrative rulings clarifying that certain Bitcoin participants do not constitute money service businesses (MSBs) under the BSA.  The rulings furthered the guidance issued by FinCEN last March, which excluded from the definition of MSB users that obtain convertible virtual currency and use such convertible virtual currency to purchase real or virtual goods or services. In the Guidance, FinCEN established Users are not MSBs because they are not engaged in money transmission services.