From the link you posted:

> The first ruling states that, to the extent a user creates or “mines” a > convertible virtual currency solely for a user’s own purposes, the user > is not a money transmitter under the BSA.

That seems to leave rather a lot of open space IMO. For example, does a POS validator create convertible virtual currency? Clearly. But is it solely for their own purposes? Do they become a money transmitter as soon as they sell their crypto? Also, only part of miner income is the block reward; there are transaction fees as well. Is a miner allowed to accept fees from sanctioned individuals for providing payment validation services?

2014 was forever ago in crypto terms of course, so I can imagine that the viewpoints of regulators have evolved together with the technology.

It probably seems unclear to you because you are not familiar with the industry and/or AML regulations. To answer your questions, cryptocurrency miners are not money transmitters, even if they sell their cryptocurrency and they can accept fees from any transactions.

Of course regulations can change, but in this case it seems unlikely unless the intention is to effectively "ban" cryptocurrency.

I didn't get the sense that WJW is unfamiliar with the industry. I read their comment as suggesting that the administrators who designed the existing regulations did so at a time when the widely understood definition of "miner" was a proof-of-work miner. If the same regulations were drafted today, would PoS validator nodes be considered functionally equivalent to PoW miner nodes? I hope not, since they aren't.

Regulations can and do change. Cryptocurrency fanatics are expanding their regulatory capture with various senators and state governments friendly to the 'movement.' I worry about the next crypto crash tanking the economy after this crypto crash.