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
On January 29, 2020, the U.S. Government Accountability Office (GAO) publicly released the results of a study which the GAO conducted on trade-based money laundering, or TBML, entitled “Countering Illicit Finance and Trade:...more
A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more
On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more
Individuals and businesses that accept and transmit virtual currency must register with the Financial Crimes Enforcement Network (“FinCEN”) as a money service business (“MSB”). Registrants must develop and maintain an...more
On April 19, 2018, the European Parliament (“EP”) adopted the European Commission’s (the “Commission”) proposal for a Fifth Anti-Money Laundering Directive (“AMLD5”) to prevent terrorist financing and money laundering through...more
In January 2018, the Korea Financial Intelligence Unit (“KoFIU”) and the Financial Supervisory Service (“FSS”) conducted a joint inspection of six Korean banks that provide trading accounts for cryptocurrency exchanges. The...more
This writer received three cold emails in two weeks asking for legal help around operating a Bitcoin ATM (BTM). Each groundbreaker asked: “What are the legal requirements for an operator putting a BTM in, say, a coffee shop?”...more
NYSE owner Intercontinental Exchange is looking to do the as-yet inconceivable: bring some order to cryptocurrencies. The plan, announced yesterday, is to launch a data feed that pull info from cryptocurrency exchanges around...more
On July 27, 2017, the Financial Crimes Enforcement Network for the Department of Treasury (FinCEN) seized the website of the digital currency exchange BTC-e for allegedly operating a multi-billion dollar money laundering...more
On Wednesday, July 27, 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $110 million fine levied against BTC-e, a digital currency exchange, for BTC-e’s alleged refusal to abide by...more
The European Commission recently published a proposal to amend the Fourth Anti-Money Laundering Directive, the legislation that specifies the anti-money laundering, or AML, and counter terrorist financing rules for EU Member...more
Last month South Carolina joined 48 other states in regulating money transmission with unanimous passage of House Bill 4554. The bill, enacting the South Carolina Anti-Money Laundering Act, provides the framework for...more
If there is one industry that needs an ethics overhaul, it has to be the financial industry. The list of transgressions continues to grow – AML/sanctions, LIBOR, Foreign Exchange Currency Cartels and Market Manipulations,...more