There have been two recent virtual currency-related actions worthy of note: (1) the Financial Crimes Enforcement Network (“FinCEN”) announced its first civil enforcement action against a virtual currency exchanger, and (2)...more
On February 4, 2015, the New York Department of Financial Services (“NYDFS”) issued for public comment a revised proposed rule to implement a “BitLicense” regulatory regime (the “2015 Proposal”). As discussed below, the 2015...more
On October 27, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings regarding virtual currency. The first administrative ruling concerns a proposed virtual currency trading and booking...more