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I am not a lawyer, but...
... the money transmission laws and regulations are written very broadly. They almost certainly apply even if you are exchanging one crypto-currency for another, and no "real money" is involved.
The only saving grace is that the laws only apply if you are operating "a business" -- so occasional lowish-value person-to-person exchanges done as a favor to friends at no markup from the current exchange rate is probably perfectly legal.