[apo]

I've seen nothing to suggest that a LN operator would be considered a money transmitter. Whats your best reason for thinking so, and why does your definition of money transmission not include miners?

[AlexCoventry]

Miners only register a transfer of value and validate it against their perspective of the current ledger. Transfer routed through a lightning channel involves explicit exchange of funds between intermediaries.

[keymone]

this is not entirely correct. in A -> B -> C payment at no point does B hold A's money with a promise to pay it forward to C.

[AlexCoventry]

B's balance with A and C fluctuate during the transfer, though, and that is enough to at least make it look like a money-transmitter relationship.

The onion routing is very unfortunate, because it means regulators are likely to treat the network as a blatant money-laundering tool.