Federal and state regulators have taken an increased interest in regulating cryptocurrencies, digital assets, and the larger blockchain ecosystem. This landscape is opaque and rapidly evolving, and many industry participants...more
9/25/2023
/ Anti-Money Laundering ,
Bitcoin ,
Bitcoin Mining ,
Blockchain ,
CFIUS ,
CFTC ,
Coinbase ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Ethereum ,
FinCEN ,
Fraud ,
Insider Trading ,
Ponzi Scheme ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Unregistered Securities
On March 19, 2021, the Financial Action Task Force (“FATF”), an intergovernmental body tasked with setting international standards aimed at preventing money laundering and terrorist financing (“FATF Standards”), released its...more
4/12/2021
/ Anti-Money Laundering ,
Cross-Border Transactions ,
Cryptocurrency ,
Digital Assets ,
FATF ,
Guidance Update ,
Information Sharing ,
Licensing Rules ,
Peer-to-Peer ,
Registration Requirement ,
Risk Mitigation ,
Terrorist Financing ,
Transfer of Assets ,
Travel Rule
After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules
On January 14, in a surprise move,...more
1/18/2021
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
Cryptocurrency ,
Financial Institutions ,
FinCEN ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Proposed Rules ,
Public Comment ,
Recordkeeping Requirements ,
Reporting Requirements ,
Travel Rule ,
U.S. Treasury ,
Uniform Commercial Code (UCC) ,
Virtual Currency
Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks -
Amid...more
11/16/2020
/ Bitcoin ,
Cryptocurrency ,
Cyber Attacks ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Enforcement Guidance ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Securities and Exchange Commission (SEC)
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
11/5/2020
/ Bank Secrecy Act ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Proposed Rules ,
Suspicious Activity Reports (SARs) ,
Travel Rule ,
Uniform Commercial Code (UCC) ,
Virtual Currency ,
Wire Transfers
On September 15, 2020, the Conference of State Bank Supervisors (CSBS) announced a “one company, one exam” program for examinations of money services businesses. These businesses, spanning from money transmitters like PayPal...more
The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more
10/2/2019
/ Anti-Money Laundering ,
Bitcoin ,
Cryptocurrency ,
Data Security ,
FATF ,
FinCEN ,
Money Services Business ,
New Guidance ,
Public Comment ,
Regulatory Requirements ,
Travel Rule ,
Virtual Currency