Business Better Podcast Episode: FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs
Crypto Year in Review 2022: Crypto Enforcement and the U.S. Treasury - The Crypto Exchange Podcast
The advent and rise of cryptocurrency have been a disruptor to the traditional currency system. Even outside the virtual aspect of the currency, the concept is novel due to its accessibility and the level of anonymity...more
Regulatory clarity in the digital assets and crypto space continues to be a moving target. Yet, the interest among policymakers and regulators worldwide has never been more pronounced. In the United States, 2024 was a pivotal...more
The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more
The President’s Working Group on Financial Markets (PWG), together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a much-anticipated Report on...more
On October 28, 2021, the Financial Action Task Force (FATF), the international body that sets standards for anti-money laundering and countering the financing of terrorism (AML/CFT), released updated guidance addressing the...more
Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more
On October 8, 2021, the Financial Industry Regulatory Authority (FINRA) issued a Regulatory Notice urging its member firms (i.e., broker-dealers) to consider how they will incorporate the U.S. Treasury Department’s...more
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
Key developments of interest over the last month include: Hong Kong: FSTB publishes consultation conclusions on virtual asset services providers licensing regime Europe: European Commission publishes proposal for Regulation...more
Recent news coverage has highlighted two potentially watershed moments in the FinTech revolution: the rise of Decentralized Finance (“DeFi”) that challenges both traditional FinTechs and legacy financial institutions alike,...more
On January 7, 2021, the original 15-day comment period ended for a proposed rule announced by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) that would impose new reporting, recordkeeping...more
The Financial Crimes Enforcement Network (“FinCEN”) recently hit the founder and primary operator of both Helix and Coin Ninja with a $60 million civil monetary penalty. These companies served as “mixers” or “tumblers” for...more
On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more
FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more
Last week, a commissioner at the Securities and Exchange Commission proposed a rule that would provide a bright line when a digital asset initially issued to raise funds to help develop a new network might later be regarded...more
U.S. Developments - U.S. Regulatory Developments - Bill Addressing Tax Treatment of Crypto Transactions Introduced to the House - On January 16, 2020, Congresswoman Suzan DelBene (WA) and Congressman David Schweikert...more
The Situation: Following the enactment earlier in 2019 of new French legislation to regulate activities related to digital assets (including cryptocurrency but excluding tokenized securities), final regulatory provisions were...more
In the course of the “Panama Paper” scandal, Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing – known as 4. Anti-Money Laundering...more
Earlier this month, the leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission released a joint statement reminding individuals...more
U.S. Developments - U.S. Federal Regulatory Developments - CFTC, FinCEN, and SEC Leaders Release a Join Statement on Digital Assets - On October 11, 2019, the heads of the Commodity Futures Trading Commission (“CFTC”),...more
BROKER-DEALER - Division of Trading and Markets and FINRA Staffs Issue Joint Statement on Broker-Dealer Custody of Digital Asset Securities - On July 8, in response to questions raised by market participants regarding...more
The FATF (FATF) is an inter-governmental body with 38 members that sets standards and promotes the implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and threats...more
France took another step towards becoming a major hub for initial coin offerings (“ICOs”) with the publication by the Accounting Rules Authority (Autorité des normes comptables or “ANC”) of Regulation No. 2018-07 of December...more
El 8 de agosto de 2018, el Director de FinCEN, Kenneth A. Blanco, pronunció un discurso en la Conferencia Técnica (Legal) Chicago-Kent Block 2018. Los puntos más destacados de sus comentarios incluyen...more
FATF Issues Virtual Currency Guidance - On October 19, the Financial Action Task Force (“FATF”) published the outcomes of its Plenary meeting. Included in the outcomes of the meeting were new recommendations related to the...more