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Virtual Currency Money Services Business Recordkeeping Requirements

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... more +
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 -
Latham & Watkins LLP

FinCEN Looks to Rein In Cryptocurrency Transactions

Latham & Watkins LLP on

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

White & Case LLP

FinCEN’s proposed regulation of virtual assets

White & Case LLP on

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

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping, verification, and reporting requirements for transactions involving virtual currency and...

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

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

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

Sheppard Mullin Richter & Hampton LLP

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Blake, Cassels & Graydon LLP

The Good, the Bad and the Ugly: Revised Regulations to PCMLTFA

The wait is over. On June 9, 2018, the Department of Finance (Department) released the long-awaited amendments to the regulations to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (Revised...more

Proskauer - New Media & Technology

FinCEN Releases Two Rulings Classifying a Bitcoin Payment System and Virtual Currency Trading Platform as MSBs

In its opening salvo bringing bitcoin under the watchful eye of the federal government, the Financial Crimes Enforcement Network (FinCEN) issued a Guidance (FIN-2013-G001) in March 2013 clarifying that anti-money laundering...more

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