Adam -- I'm afraid you may have somewhat misunderstood the motivation behind the Identity Agnostic paper. In no way is it intended as a way of not facing the music wrt regulators in the country(s) where such an institution has offices. The IA approach is intended as an possible alternative for an institution that might otherwise license from Chaum. The regulators I've discussed this with are primarily concerned with how money moves into and out of a digital cash system. The fact that small payments cannot be traced from buyer to seller is not at the top of their list of concerns -- it's already a basic fact of life for them in existing payment systems. They are also not oblivious to the privacy concerns inherent in an institution logging masssive amounts of counterparty data about small transactions. I would strongly discourage anyone from trying to set up a garage- type operation. While regulators clearly don't appreciate the subtleties of this stuff, they can spot an illegal bank or an unlicensed money transmitter from a mile away. If your concern is creating account anonymity, then you're going to need to set up outside of the US. Do be aware that even the more relaxed countries of the world have regulations that cover this sort of thing, and they are especially interested in making sure you at least pay the appropriate licensing fees.