Bitcoins and SAR Narratives

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You probably know about Bitcoin, unless you have been living in total seclusion for the last few years. The big controversy usually centers on determining if it is legal tender. But imagine if you are confronted with a transaction involving Bitcoin. Do you file a Suspicious Activity Report (“SAR”)?

It so happens that the Financial Crimes Enforcement Network (“FinCEN”) has been giving that very concern laser-like attention! In July 2014’s “SAR Stats,” FinCEN observed that the “rapid adoption and price fluctuation of Bitcoin” has put convertible virtual currencies in the spotlight over the past year. The same attributes of virtual currencies that attract lawful users, such as the capacity for anonymity as well as their speed and global reach, attract criminal actors engaged in illicit financing. FinCEN is observing a rise in the number of SARs flagging virtual currencies as a component of suspicious activity. Bitcoin is consider one of the “emerging payment methods.” Consequently, it is important to understand virtual currencies in order to properly complete the SAR Narrative.

So let’s define Bitcoin. ...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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