News & Analysis as of

Banks Money Services Business

The Rodman Law Group, LLC

The Corporate Transparency Act Reporting Exemptions

The Corporate Transparency Act mandates certain reporting requirements for beneficial ownership information for certain companies, with the goal of preventing the illicit use of anonymous shell companies for financial crimes....more

Ballard Spahr LLP

Bipartisan Group of Senators Re-Introduce the Digital Asset Money Laundering Act

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Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more

Troutman Pepper

Bank Secrecy Act's Crypto Expansion Is on the Horizon

Troutman Pepper on

The Dec. 14, 2022, introduction of the Digital Asset Anti-Money Laundering Act by Sens. Elizabeth Warren, D-Mass., and Roger Marshall, R-Kan., marks the end of a tumultuous year in the cryptocurrency industry that saw a...more

McGuireWoods LLP

FinCEN Issues Statement on BSA Due Diligence for Independent ATM Owners and Operators

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On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a Statement on Bank Secrecy Act Due Diligence for independent ATM owners and operators. The purpose of the statement is to “provide clarity to banks...more

Blake, Cassels & Graydon LLP

Réglementation des paiements de détail au Canada : La Loi sur les activités associées aux paiements de détail est arrivée

Comme il était prévu et comme il a été annoncé le 30 avril 2021 dans le Budget 2021 : Une relance axée sur les emplois, la croissance et la résilience, le gouvernement fédéral a publié le projet de loi C-30, qui renferme...more

Blake, Cassels & Graydon LLP

Regulation of Retail Payments in Canada - The Retail Payments Activities Act Has Arrived

As was expected and announced in Budget 2021: A Recovery Plan for Jobs, Growth and Resilience, on April 30, 2021 the federal government released Bill C-30 containing, among other things, a draft of the long-awaited Retail...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping, verification, and reporting requirements for transactions involving virtual currency and...

On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to establish new requirements for convertible virtual currency (CVC) and legal tender digital asset (LTDA)...more

Sheppard Mullin Richter & Hampton LLP

Joint Statement on Digital Assets from CFTC, SEC and FinCEN - a Warning to the Crypto Industry regarding Anti-Money Laundering and...

The leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission (the “Agencies”) issued a joint statement to remind persons engaged in...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Releases Advisory for Banks, MSBs on Potentially Illicit Transactions with Iran

• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...more

Nelson Mullins Riley & Scarborough LLP

States Launch Standardized Licensing Pilot Program for Money Services Businesses

Seven states have agreed to a multi-state compact standardizing key aspects of money services business (MSB) licensing. As of today, Georgia, Illinois, Kansas, Massachusetts, Tennessee, Texas, and Washington have joined into...more

Perkins Coie

Governor Signs Into Law Amendments to Washington’s Uniform Money Services Act

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On April 18 the governor of Washington signed into law amendments proposed by the Washington Department of Financial Institutions (“DFI”) in December of last year, to the state’s Uniform Money Services Act, including...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Manatt, Phelps & Phillips, LLP

Digital Currency Corner - What FinCEN’s Denial of Payment Processing Exemption for Virtual Currency-Related Businesses Means for...

Why it matters - The rapid evolution of virtual and digital currencies has spawned significant activity in several federal agencies with implications potentially for traditional entities in certain cases. In addition to...more

Morrison & Foerster LLP

FinCEN Issues Statement Encouraging Banks to Evaluate Money Services Businesses on a Case-by-Case Basis

Morrison & Foerster LLP on

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

Perkins Coie

FinCEN Releases Statement Encouraging Banks to Offer Services to Money Service Businesses (MSBs)

Perkins Coie on

In what may be good news for emerging virtual currency companies and emerging payments companies, the Financial Crimes Enforcement Network (“FinCEN”) released a public statement yesterday regarding the willingness of banks to...more

Katten Muchin Rosenman LLP

Texas Department of Banking Issues Guidance on Treatment of Virtual Currency

On April 3, the Texas Department of Banking released a supervisory memorandum on the regulatory treatment of virtual currencies such as bitcoin under the Texas Money Services Act. The guidance clarified that virtual currency...more

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