[coachtrotz]

Facebook Payments Inc is a state licensed Money Transmitter in all states, and is registered with FinCEN as a Money Services Business so they would certainly understand the requirements as they're subject to audits by State regulators.

Source: https://www.nmlsconsumeraccess.org/EntityDetails.aspx/COMPAN...; https://www.fincen.gov/msb-registrant-search