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
On December 4, 2024, the CFTC's Division of Enforcement ("Division") released its enforcement results for Fiscal Year 2024. The results reflected an all-time high for monetary relief, mainly from its resolution of off-channel...more
A shrinking legislative calendar and the fallout from November’s election results – no matter which party gains the upper hand in the battle for control of Congress – are likely to doom lawmakers’ efforts to pass...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
Since the announcement of its Fintech strategy in November 2017, the Bermuda government has positioned Bermuda as a market-leading jurisdiction with respect to Fintech, with a view to Bermuda operating as an innovation hub...more
In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more
On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
Hong Kong regulators recently brought criminal enforcement actions against virtual asset trading platform JPEX and individuals associated with the platform. This case has become the first opportunity for local authorities to...more
Approaches and developments - The Cayman Islands has long been a leading offshore jurisdiction for investment funds, as well as a significant global financial centre overall. It is therefore not surprising that, reflecting...more
The cryptocurrency industry has a target on its back – and perhaps justifiably so. The SEC, CFTC and OFAC have been bringing a number of regulatory enforcement actions, including against Bittrex, Inc. ($24,280,829.20 in...more
On May 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a roughly $7.6 million settlement with a Massachusetts-based online trading and settlement platform to resolve potential civil...more
Despite the ongoing “Crypto Winter,” the use of NFTs continues to rise. NFTs are associated most often with pictures, videos, and music, but developers have been finding many new and useful applications for them. As the...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
In a new development, the Commodity Futures Trading Commission (CFTC or Commission) has charged that “voting members” of the Ooki DAO are liable for its violations of the Commodity Exchange Act (CEA) and CFTC regulations by...more
The long-awaited infrastructure bill took a new turn in recent days as a bipartisan group of senators filed an amendment which would clarify the cryptocurrency-related provisions buried in the legislation. Senators Ron Wyden...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
Beyond creative works and consumer products, NFTs open up new avenues for IP monetisation in the technology, life sciences, and pharmaceutical industries. Non-fungible tokens (NFTs), one-of-a-kind cryptoassets stored on...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
Incorporating in the Seychelles but Allegedly Operating in the U.S. Spells Trouble for Company and its Founders - The Bitcoin Mercantile Exchange, or BitMEX, is a large and well-known online trading platform dealing in...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
The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...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
Federal regulators start to address some of the recent questions about digital assets such as tokens and virtual currencies, though many questions remain. U.S. Regulators and Congress are grappling with how to manage the...more
U.S. Developments - Regulatory Developments - CFTC Announces Two Events Designed to Encourage FinTech Innovation - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) announced two events designed to...more