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Cryptocurrency: Legal Developments and Outlook

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

FATF Releases Proposed Updates to Cryptocurrency Regulation Guidance

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

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

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

Patchwork of Cryptocurrency Regulators Increasingly Stitch Together Cooperative Enforcement Efforts

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

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

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

CSBS Announces “One Company, One Exam” Program for Examinations of Money Services Businesses

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

Fake It Till You Make It: The Travel Rule And Virtual Currencies

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

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