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FinCEN responds to a letter seeking an administrative ruling on whether a company's Bitcoin mining operations and disposal of mined Bitcoins would make it a money services business (MSB) under the Bank Secrecy Act (BSA). The company may use the mined Bitcoins to purchase goods or services, convert them to legal tender, or transfer them to the owner. FinCEN's regulations define an MSB as a person doing business in one or more capacities, including money transmission services. A money transmitter is a person that provides money transmission services or is engaged in the transfer of funds. The regulations also identify circumstances under which a person's activities would not make them a money transmitter. FinCEN issued guidance on virtual currencies, defining currency and virtual currency, and addressing participants in virtual currency arrangements, including exchangers, administrators, and users. The guidance states that an administrator or exchanger of convertible virtual currencies is a money transmitter, unless an exemption applies. A user who obtains convertible virtual currency and uses it to purchase goods or services is not an MSB. FinCEN concludes that a user who mines Bitcoins and uses them solely for their own purposes is not an MSB, as these activities do not involve accepting or transmitting convertible virtual currency.