Here's a good analysis of the Linden Lab's handling of third party sellers of Linden Dollars by Alex Kadochnikov, a New Jersey lawyer who's been closely following the legal ramifications of virtual currencies in recent months. As I noted recently, Linden Lab hastily launched an authorized Linden Dollar reseller program to allow (some) third parties to sell Linden Dollars, apparently in response to new regulations from the US Treasury department. According to Kadochnikov, these third parties will have to register with the US government too:
Resale of Linden Dollars does not fit exactly under the FinCEN’s definition of an exchanger, but their engagement with virtual currency likely still means that FinCEN views them as money transmitters. Thus, under present regulations resellers have six months to register with FinCEN.
FinCEN stands for the Financial Crimes Enforcement Network, a division of the United States Treasury department. And connecting this to an earlier post by Kadochnikov, it sounds like registration is going to be pretty complicated, time-consuming, and require lots of legal help.