FinCEN recently issued new guidance on existing laws regarding ICOs and their relation to money laundering laws. This twitter thread does a nice job of summarizing key points.
From the guidance itself, the "CVC" being Tangram:
In any of these scenarios, the seller
of the CVC is a money transmitter, acting in the role of administrator, because at the
time of the initial offering the seller is the only person authorized to issue and redeem
(permanently retire from circulation) the new units of CVC.76 The status of the seller
as a money transmitter is not impacted by the coordinated or simultaneous sales;
the timing of acceptance of one type of value and transmission of the other type (i.e.,
whether the exchange happens instantaneously or at a later date); or by the fact that the
payment system may migrate from one operational status to another at any point in its
lifetime (for example, changing from a centralized, administrator-controlled system at
origin to a decentralized, protocol-driven system after the initial sale).
From section 5.2, which discusses ICOs that aren't securities, presumably including Tangram.
This makes Tangram a money transmitter, which has various requirements that Tangram is not fulfilling (and which would be unreasonable for Tangram to be able to fulfill), including collecting the identity of participants and having a dedicated employee who ensures the laws are being followed.
