News & Analysis as of September 24, 2024

Cybersecurity

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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 -

NYDFS, crypto payment service provider resolve AML/cybersecurity violations

Orrick, Herrington & Sutcliffe LLP on 4/13/2023

On March 16, NYDFS issued a consent order against a payment service provider for allegedly failing to comply with the state’s virtual currency and cybersecurity regulations. The company was licensed to engage in virtual...more

Louisiana Adopts Virtual Currency License

Shipkevich PLLC on 1/18/2023

Louisiana has become the first state to follow New York's lead in issuing a crypto-specific license, accepting Louisiana Virtual Currency Business Activity (VCBA) license applications as of January 1, 2023. All entities...more

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

BakerHostetler on 1/17/2023

On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

New York State Department of Financial Services Publishes First Crypto Industry Consent Order

BakerHostetler on 8/15/2022

On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...more

Global Markets May Face Risk of Virtual Currency Abuse as Russian Actors Seek to Circumvent Sanctions

K2 Integrity on 3/14/2022

The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...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

White House Focused on Combating Ransomware

Robinson+Cole Data Privacy + Security Insider on 7/16/2021

Ransomware attacks are frequent and escalating as we speak. Double extortion scams are hitting companies at a dizzying pace, and catching companies, large and small, off-guard. U.S. President Joseph Biden warned Russian...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

New FinCEN Anti-Money Laundering Priorities

Foley & Lardner LLP on 7/13/2021

Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more

FinCEN Issues Anti-Money Laundering and Countering the Financing of Terrorism Priorities

King & Spalding on 7/8/2021

FinCEN announces eight areas of focus and advises preparation for issuance of new regulations - On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more

FinCEN Issues Guidance on Ransomware Attacks

Jones Day on 10/23/2020

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

Virtual Currency as a Threat to National Security?

King & Spalding on 3/12/2020

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

SEC Announces 2018 National Examination Priorities

Troutman Pepper on 2/19/2018

The Securities and Exchange Commission's Office of Compliance Inspections and Examinations (OCIE) recently announced its 2018 national examination priorities, which are broken down into five categories...more

Your Daily Dose of Financial News

Robins Kaplan LLP on 1/19/2018

NYSE owner Intercontinental Exchange is looking to do the as-yet inconceivable: bring some order to cryptocurrencies. The plan, announced yesterday, is to launch a data feed that pull info from cryptocurrency exchanges around...more

A System of Voluntary Self-Identification in the World of Virtual Currencies

Locke Lord LLP on 10/7/2016

On 5th July 2016, the European Commission (the “Commission”) published a proposal for a Directive amending the Fourth Money Laundering Directive (“Proposed Directive”), which sets out, amongst other things, to bring into...more

The CSBS Finalizes Model Framework for Virtual Currencies

Morrison & Foerster LLP on 9/29/2015

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

Financial Services Weekly News - September 2015 #3

Goodwin on 9/17/2015

Regulatory Developments: CFTC Grants Temporary Registration as SEF to LedgerX Bitcoin Options Exchange and Clearing House - On Sept. 10 the CFTC announced that it had issued an Order of Temporary Registration as a...more

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Virtual Currency › Anti-Money Laundering › Cybersecurity

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