{"asOf":"2026-09-05","merchant":"SSDF INC","kind":"florida","statute":"Fla. Stat. ch. 560 (Money Services Businesses)","parts":[{"id":"part-ii","title":"Part II — payment instruments and funds transmission","body":"The transmission question. Intermediated models — receive, then send onward — are the risk. First-party sale of a digital SKU settled by Coinbase Business is retail, not a third-party send."},{"id":"part-v","title":"Part V — payment stablecoin issuers","body":"Florida's stablecoin-issuer chapter. SSDF accepts USDC. SSDF does not issue a payment stablecoin. Circle is the USDC issuer. GENIUS is the federal clerk for issuers, not for retailers."},{"id":"part-vi","title":"Part VI — virtual currency kiosk businesses","body":"Kiosk operators. Irrelevant to an electronic catalog. Listed so an agent does not confuse a storefront with an ATM."}],"hb273":"HB 273 (effective 1 Jan 2023) put a statutory definition of virtual currency inside Florida money transmission. Two-party sales from a dealer's own inventory without holding customer funds remain the carve-out to confirm with counsel. Holding customer crypto to send later is the other side of that line.","noAgentOfPayee":"Florida ch. 560 lacks a Texas/California-style agent-of-the-payee exemption and a clean closed-loop gift-card walkaway. OFR declaratory practice looks at the economics. Contract paper that says 'we are the merchant's agent' is not bulletproof here.","closedLoop":"Desk Credits are closed-loop store credit, redeemable only for SSDF SKUs, never cash, never a third-party merchant. That is the existing Ch. 560 posture. Opening those credits to other brands would reopen the analysis.","firstPartyUsdc":"A Florida retailer that prices in USD and lets Coinbase Business take USDC on Base for its own SKUs is not, on that fact alone, a money transmitter. A marketplace, an agent wallet SSDF custodied, or a card SSDF issued would be a different fact pattern.","residual":"The national BaaS pitch (API + sponsor bank + FBO + program manager) is written for a 50-state product. Florida is the residual risk point because the statute does not give the same exemptions. This atlas exists so an agent does not paste a national pitch over ch. 560."}