All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...more
The crypto industry is evolving rapidly, and regulatory enforcement is keeping pace. Businesses engaged in crypto transactions, custody, lending, trading, or payments must navigate know your customer (KYC) and anti-money...more
Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more
On August 19, the U.S. Treasury Department officially withdrew a contentious proposal from 2020 that aimed to impose know-your-customer requirements on non-custodial cryptocurrency wallets....more
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more
ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more
Binance to Pay Historic $4 Billion Fine - Binance Holdings Limited, the operator of the world’s largest cryptocurrency exchange, agreed to pay $4.3 billion to resolve allegations that it violated the Bank Secrecy Act (BSA)...more
U.S. Senators Elizabeth Warren and Roger Marshall are introducing the Digital Asset Anti-Money Laundering Act (the "Act"), with the aim of bringing the crypto and digital asset ecosystem under existing anti-money laundering...more
On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...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 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 August 10, 2021, the Commodity Futures Trading Commission (CFTC) and the Financial Crimes Enforcement Network (FinCEN) announced a near-record settlement of $100 million with BitMEX, a cryptocurrency derivatives exchange....more
As cryptocurrency’s market cap surpasses the $2.5 trillion mark and continues to climb, global regulators have turned their attention to understanding and addressing the risks surrounding digital assets. In recent years,...more
Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more
On October 8, 2020, Attorney General William Barr announced the release of a Cryptocurrency Enforcement Framework produced by the Department of Justice (DOJ) Cyber-Digital Task Force. The 83-page framework is intended to help...more
Treasury Secretary Steven Mnuchin remarked before a hearing of the Senate Finance Committee three weeks ago that “significant new requirements at FinCEN” for cryptocurrencies would be introduced quickly, in response to...more
The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more
As the value of bitcoin continues to soar (USD:BTC this past weekend exceeded $19,000.00:1), we thought that now would be a good time to emphasize the need to ensure regulatory compliance with the many federal and state AML...more