In recent months, US federal and state regulators have continued to focus on Bitcoin and the adoption of a regulatory framework for it and other "virtual currencies," as well as the enforcement of existing securities laws to offerings denominated in bitcoins. This advisory addresses the following developments.
- The Financial Crimes Enforcement Network (FinCEN) recently released two administrative rulings ("Administrative Rulings") clarifying the application of the Bank Secrecy Act (BSA) and FinCEN regulations to Bitcoin. The Administrative Rulings elaborate upon guidance that FinCEN previously issued ("Prior Guidance").
Please see full advisory below for more information.