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 November 10, 2014, the Financial Crimes Enforcement Network (FinCEN) issued a Statement addressing bank “de-risking,” often described as the practice of closing accounts or refusing to open accounts for particular types...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