Yes, that is exactly what I meant.

I believe this is a prelude to prosecuting entirely new categories of "crime". Such as inadvertently or naively doing business with the wrong country even when the sale has nothing to do with strategic goods or services. (IE, my LLC buys some part from a Russian guy, then is prosecuted under FinCEN.

Reading up on this new law/regulation, it appears that its demand for registration is focused specifically upon small businesses, LLCs and S-corps. Exactly in the same vein as the new $600 threshold for reporting 1099 income.

There is a large list of exempt business formats that seem to scream for oversight. Here are the exemptions.

1 Securities reporting issuer
2 Governmental authority
3 Bank
4 Credit union
5 Depository institution holding company
6 Money services business
7 Broker or dealer in securities
8 Securities exchange or clearing agency
9 Other Exchange Act registered entity
10 Investment company or investment adviser
11 Venture capital fund adviser
12 Insurance company
13 State-licensed insurance producer
14 Commodity Exchange Act registered entity
15 Accounting firm
16 Public utility
17 Financial market utility
18 Pooled investment vehicle
19 Tax-exempt entity
20 Entity assisting a tax-exempt entity
21 Large operating company
22 Subsidiary of certain exempt entities
23 Inactive entity