Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros – The Payments Law Podcast
Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more
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
Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more
Blockchain analysis is a powerful tool that provides insight into what is happening on a blockchain network. Who is trading with whom? Which wallets are most active on decentralized finance exchanges? Which wallets are...more
U.S. regulators are signaling heightened expectations for anti-money laundering compliance within the crypto industry. Although FinCEN issued guidance in 2013 interpreting virtual currency “administrators” and “exchanges” as...more
On October 11, 2022, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) acted in parallel to issue the first joint action in the cryptocurrency market against Bittrex. Bittrex...more
Government attitude and definition - As in many countries, the regulation of cryptocurrencies in Canada is divided among various levels of government and administrative agencies, depending on the nature of the activity...more
The Abu Dhabi Global Market (ADGM) has recently published new financial services amending regulations and various amended rulebook modules. These wide-ranging measures update ADGM’s rules on environmental matters, virtual...more
On May 24, 2022, nine Canadian cryptocurrency companies—Wealthsimple, CoinSmart, Netcoins, Shakepay, VirgoCX, Tetra Trust, BlocPal, Balance and Coinsquare—announced their membership in the Travel Rule Universal Solution...more
Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April...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
The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...more
Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more
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
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
The incoming Biden team will need to quickly address significant digital asset issues, including a major enforcement action and a significant proposed FinCEN rule initiated in the final days of the outgoing administration. ...more
Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more
A new proposal would subject financial institutions and exchanges to onerous recordkeeping and reporting requirements for certain digital currency transactions. In a surprise release in the waning days of the Trump...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
On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury announced highly anticipated and controversial new proposed requirements designed to mitigate illicit finance risks...more
On December 18, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposal to impose on banks and money service businesses (“affected institutions”) a new set of rules for digital currency transactions involving...more
The news that one of the world’s leading online payments companies will allow its 325 million account holders to conduct transactions using cryptocurrencies serves as a high-profile indicator of the increasing maturity of...more
On October 1, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to alert Financial Institutions (FI) relating to “predominant trends, typologies, and potential indicators of ransomware and associated...more
On October 19, 2020, The Financial Crimes Enforcement Network (FinCEN) announced its first action against a bitcoin mixer: a $60 million civil penalty against Larry Dean Harmon. Harmon was the founder and operator of Helix...more
The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more