The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more
5/22/2019
/ Anti-Money Laundering ,
ATMs ,
Bank Secrecy Act ,
Casinos ,
Compliance ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Exemptions ,
Financial Institutions ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Money Laundering ,
Money Services Business ,
Money Transfer ,
New Guidance ,
Payment Processors ,
Peer-to-Peer ,
Risk Assessment ,
Terrorism Funding ,
Trading Platforms ,
Virtual Currency
Through two publications on April 3, 2018, the Staff of the Securities and Exchange Commission provided greater clarity on the application of the federal securities laws to blockchain-based “digital assets.”1 While the Staff...more
The U.S. Securities and Exchange Commission announced two settled enforcement actions on November 16, 2018, imposing registration requirements and civil penalties against issuers of initial coin offerings (ICOs) for failing...more
12/6/2018
/ Broker-Dealer ,
Civil Monetary Penalty ,
Compliance ,
Digital Assets ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Howey ,
Initial Coin Offering (ICOs) ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Settlement ,
Unregistered Securities
The staff of the Divisions of Enforcement and Trading and Markets (collectively, Staff) of the U.S. Securities and Exchange Commission (SEC) on March 7, 2018 jointly issued a statement on digital asset trading platforms...more
3/28/2018
/ Alternative Trading System (ATS) ,
Broker-Dealer ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Investor Protection ,
Investors ,
Market Participants ,
Personal Liability ,
Registration Requirement ,
Securities ,
Securities and Exchange Commission (SEC) ,
Token Sales
The U.S. Commodity Futures Trading Commission’s (CFTC) LabCFTC office on October 17, 2017 issued A CFTC Primer on Virtual Currencies (Primer) indicating, among other things, that certain initial coin offerings (ICOs) within...more
10/23/2017
/ Bitcoin ,
CFTC ,
Commodities ,
Derivatives ,
FinTech ,
Initial Coin Offering (ICOs) ,
Jurisdiction ,
New Guidance ,
Popular ,
Risk Factors ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
Since January 2017, more than $2 billion has been raised through the rapidly growing market for so-called “token sales” or “initial coin offerings” (ICOs). The U.S. Securities and Exchange Commission (SEC) announced on July...more
10/7/2017
/ BaFin ,
Banking Restrictions ,
Banks ,
China ,
Corporate Counsel ,
Corporate Issuers ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Financial Conduct Authority (FCA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Germany ,
Hong Kong ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Initial Coin Offering (ICOs) ,
Investors ,
Monetary Authority of Singapore ,
People's Bank of China ,
Securities and Exchange Commission (SEC) ,
Singapore ,
Token Sales ,
UK ,
Unregistered Securities ,
Young Lawyers