[lottin]

They move money from one party to another by updating a ledger. That's what money transmitters do. Not being in possession of the funds, or the fact that the specific entity that moves the funds is chosen at random, doesn't change the fact that they're money transmitters.

[from]

It's a real shame the Treasury Department officially disagrees with you in spite of the fact that there a lot of hardliners there (likely the same types who think e-gold was a money transmitter) who would love to agree with you.