News & Analysis as of September 25, 2024

Virtual Currency › AML/CFT

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on 12/8/2023

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

Foodman CPAs & Advisors on 11/29/2023

El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more

Terrorist Financing FinCEN Red Flags

Foodman CPAs & Advisors on 11/29/2023

On 10/20/23, Terrorist Financing Red Flags were issued by FinCEN to assist financial institutions in identifying funding streams for the terrorist organization Hamas in response to Hamas’s terrorist attack on the people of...more

Alerta De FinCEN De “Masacre De Cerdos”

Foodman CPAs & Advisors on 11/17/2023

El 8/9/23, FinCEN emitió una alerta sobre una estafa frecuente de inversión en moneda virtual comúnmente conocida como ““masacre de cerdos” ” o “Pig Butchering”. La alerta de FinCEN sobre la “masacre de cerdos” aborda las...more

FinCEN’s Pig Butchering Alert

Foodman CPAs & Advisors on 10/26/2023

On 9/8/23, FinCEN issued an alert on a prevalent Virtual Currency Investment Scam commonly known as “Pig Butchering”. FinCEN’s Pig Butchering alert addresses “Pig butchering” scams which resemble the practice of fattening a...more

BVI VASP Update: A Two Step Approach

Walkers on 10/28/2022

As widely expected, the British Virgin Islands ("BVI") is shortly bringing into force new legislation to implement the Financial Action Task Force's standards on virtual assets and virtual asset service providers (known as...more

Treasury Plans Significant Actions to Curb Illicit Digital Asset Financing

BakerHostetler on 10/17/2022

As part of a coordinated effort with the U.S. Secretary of State, Attorney General, Secretary of Commerce, Secretary of Homeland Security, Director of the Office of Management and Budget, Director of National Intelligence,...more

OFAC Sanctions Virtual Currency Mixer Tornado Cash

Dechert LLP on 9/16/2022

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more

FATF Issues Targeted Update Report on Implementation of AML/CFT Standards on Virtual Assets

Ballard Spahr LLP on 7/20/2022

The Financial Action Task Force (“FATF”) recently issued an updated review of the implementation of its anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) standards to financial activities involving Virtual...more

2021 Anti-Money Laundering and Sanctions Year in Review

Jones Day on 3/10/2022

2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more

Federal Regulators Move To Regulate Stablecoins Through Banking Laws Plus New Legislation

Skadden, Arps, Slate, Meagher & Flom LLP on 11/17/2021

The President’s Working Group on Financial Markets (PWG), together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a much-anticipated Report on...more

FATF Updates Its Global Guidelines for the Regulation of Virtual Assets With an Eye to Emerging Technologies

Skadden, Arps, Slate, Meagher & Flom LLP on 11/12/2021

On October 28, 2021, the Financial Action Task Force (FATF), the international body that sets standards for anti-money laundering and countering the financing of terrorism (AML/CFT), released updated guidance addressing the...more

Sanctions 2.0: US Treasury Department announces results of sanctions policy review and OFAC releases compliance guidance for the...

Eversheds Sutherland (US) LLP on 10/29/2021

The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Proskauer - Blockchain and the Law on 10/28/2021

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

FINRA Issues Guidance Encouraging Firms To Prepare for Forthcoming Anti-Money Laundering Rules

Skadden, Arps, Slate, Meagher & Flom LLP on 10/19/2021

On October 8, 2021, the Financial Industry Regulatory Authority (FINRA) issued a Regulatory Notice urging its member firms (i.e., broker-dealers) to consider how they will incorporate the U.S. Treasury Department’s...more

OFAC Imposes New Sanctions to Thwart Ransomware

WilmerHale on 9/24/2021

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

WilmerHale on 7/15/2021

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on 7/7/2021

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Global Payments Newsletter, June 2021

Hogan Lovells on 6/16/2021

Key developments of interest over the last month include: Hong Kong: FSTB publishes consultation conclusions on virtual asset services providers licensing regime Europe: European Commission publishes proposal for Regulation...more

Regulatory Considerations for New Iterations in the Crypto and Digital Asset Space

BCLP on 4/9/2021

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

FinCEN Proposes New Reporting, Recordkeeping and Verification Requirements for Transactions Involving Unhosted Wallets

Skadden, Arps, Slate, Meagher & Flom LLP on 1/20/2021

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

Proposed Rules for Transactions with Unhosted Virtual Currency Wallets

K2 Integrity on 1/6/2021

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

Bitcoin “Mixer” That Anonymizes Transactions Shaken With $60 Million Penalty From FinCEN

Vinson & Elkins LLP on 11/5/2020

The Financial Crimes Enforcement Network (“FinCEN”) recently hit the founder and primary operator of both Helix and Coin Ninja with a $60 million civil monetary penalty. These companies served as “mixers” or “tumblers” for...more

Cryptocurrency 101 – DOJ’s New Cryptocurrency Enforcement Framework Provides Guidance And Promises Of Heightened Scrutiny Of...

Vinson & Elkins LLP on 10/22/2020

On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more

FATF Identifies Red Flags for Virtual Assets and Money Laundering

Ballard Spahr LLP on 9/18/2020

The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...more

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Virtual Currency › AML/CFT

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