Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros – The Payments Law Podcast
Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more
On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more
On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more
For the second straight year, the majority of whistleblower tips received by the Commodity Futures Trading Commission (CFTC) Whistleblower Program were related to cryptocurrency fraud. On October 31, the CFTC released its...more
Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more
On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced the Digital Asset Anti-Money Laundering Act of 2022 (the Act) that would extend anti-money laundering and countering of the financing...more
The collapse of cryptocurrency exchange FTX has been widely reported across the world. One interesting exception to the fallout appears to involve U.S. customers, according to a tweet from FTX’s former CEO. We’ve received...more
On May 19, Alessio Evangelista, the Associate Director of the Enforcement and Compliance Division of FinCEN, presented at the Chainalaysis Links Conference on the topic of “Intersection of Cryptocurrencies and National...more
Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April...more
The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...more
Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more
Recent news coverage has highlighted two potentially watershed moments in the FinTech revolution: the rise of Decentralized Finance (“DeFi”) that challenges both traditional FinTechs and legacy financial institutions alike,...more
The incoming Biden team will need to quickly address significant digital asset issues, including a major enforcement action and a significant proposed FinCEN rule initiated in the final days of the outgoing administration. ...more
On January 7, 2021, the original 15-day comment period ended for a proposed rule announced by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) that would impose new reporting, recordkeeping...more
Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more
A new proposal would subject financial institutions and exchanges to onerous recordkeeping and reporting requirements for certain digital currency transactions. In a surprise release in the waning days of the Trump...more
A controversial proposed rule from the Financial Crimes Enforcement Network would bring bank-like regulation of virtual asset transactions, including the first broadly-applied AML reporting requirement in at least two...more
Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more
On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury announced highly anticipated and controversial new proposed requirements designed to mitigate illicit finance risks...more
On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to establish new requirements for convertible virtual currency (CVC) and legal tender digital asset (LTDA)...more
On December 18, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposal to impose on banks and money service businesses (“affected institutions”) a new set of rules for digital currency transactions involving...more
On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more
On October 1, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to alert Financial Institutions (FI) relating to “predominant trends, typologies, and potential indicators of ransomware and associated...more
On October 19, 2020, The Financial Crimes Enforcement Network (FinCEN) announced its first action against a bitcoin mixer: a $60 million civil penalty against Larry Dean Harmon. Harmon was the founder and operator of Helix...more
The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more