On October 11, 2018, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released an advisory (the Advisory) intended to help money services businesses (MSBs) and foreign financial institutions...more
On March 29, 2017, Perkins Coie partner Dax Hansen and associate Josh Boehm were invited to the Cyber Initiative at Stanford Law School to deliver a presentation on several cutting-edge legal issues relating to blockchain...more
4/15/2017
/ Bank Secrecy Act ,
Bankruptcy Code ,
Banks ,
Bitcoin ,
BitLicense ,
CFTC ,
Commodities ,
Custody Rule ,
FinCEN ,
Income Taxes ,
Money Transmitter ,
Ownership Requirements ,
Personal Property ,
Popular ,
Securities ,
Securities and Exchange Commission (SEC)
In this white paper, we analyze the treatment of bitcoin under applicable U.S. property law. We conclude that property interests should exist in bitcoin under such law, and that multiple sources of persuasive authority...more
3/30/2017
/ Bankruptcy Code ,
Bitcoin ,
BitLicense ,
CFTC ,
Civil Forfeiture ,
Commodities ,
FDIC ,
FinCEN ,
Intangible Property ,
IRS ,
Popular ,
Property Ownership ,
UFADAA ,
Uniform Commercial Code (UCC) ,
Virtual Currency
Federal authorities announced this week a settlement with Ripple Labs Inc. and its subsidiary, XRP Fund II, resolving an investigation by FinCEN and the Department of Justice into violations of the Bank Secrecy Act. ...more
In what may be good news for emerging virtual currency companies and emerging payments companies, the Financial Crimes Enforcement Network (“FinCEN”) released a public statement yesterday regarding the willingness of banks to...more
On April 29, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a series of administrative rulings determining whether five different companies constitute money services...more
Overview -
On January 30, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued two administrative letter rulings that clarify the application of FinCEN’s regulations to...more
A political action committee has sought an advisory opinion from the Federal Election Commission (FEC) as to whether bitcoins can be accepted as political contributions and, if so, how bitcoins should be characterized and...more
In response to the SEC’s first civil complaint arising from online virtual currency trading, alleged Bitcoin Ponzi schemer Trendon Shavers recently challenged the district court’s authority to hear the case. ...more
Asset Seizures and Arrests Mark Recent Federal Virtual Currency Enforcement Actions -
Federal authorities have initiated several recent enforcement actions that are indicative of continuing regulatory changes in the...more
To address a perceived gap in regulatory treatment of increasingly popular virtual currencies, including Bitcoin, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) released new guidance on...more