However, if I agree that the bank act as an intermediary and lend out the gold, that is a different situation.

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The Vatican has made it clear it is willing to act as an intermediary (or "interpreter" as it likes to call it) between Washington and Havana.

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Payments over that amount would have to be processed via a financial intermediary subject to the Anti-Money Laundering Act (AMLA).

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Title III of the JOBS Act adds new Section 3(h) to the Exchange Act which requires the SEC to exempt, conditionally or unconditionally, an intermediary operating a funding portal from the requirement to register with the SEC as a broker.

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