Report Offers Weak Insight on Causation but Lists Steps that Treasury Can and Should Take - The Department of Treasury (“DOT”) recently released its first ever strategy report (the “Strategy”) on the topic of de-risking,...more
On December 16, in Adasa Inc. v. Avery Dennison Corporation, the Federal Circuit upheld patentability of claims reciting an RFID transponder with storage for a particular type of serial number—affirming the district court’s...more
Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more
The Canadian federal government has fulfilled its promise to expand Canada’s anti-money laundering (AML) regime to cover crowdfunding platforms and certain payment service providers (PSPs) that previously operated outside the...more
Issuers should be aware that Ginnie Mae interpreting its MBS guide in a manner that departs from VA circular 26-19-22, and the plain reading of statutory language with respect to the beginning and ending dates used to...more
Over the last 20 years, commerce, finance, and banking have become increasingly digital. Anti-money laundering (AML) regulators have found themselves catching up with the pace of technological innovation.1 As AML regulators...more
A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end...more
In case it was not already clear, the U.S. Department of Justice recently confirmed that ensuring the use of cryptocurrency “is safe, and does not imperil our public safety or our national security, is vitally important to...more
On May 26, 2020, the Financial Crimes Enforcement Network, (“FinCEN”) issued a notice in the Federal Register updating cost estimates related to compliance with filing suspicious activity reports (SARs). Under the Bank...more
FinCEN has issued updated guidance addressing the use of crypto currency and other convertible virtual currency (CVC). A portion of this guidance addresses the use of CVC in games. The guidance does not establish any new...more
Editor's Note - In This Issue. State regulators agreed to a multistate compact to standardize key components of the licensing process for money services businesses (MSBs); the Board of Governors of the Federal Reserve...more
Starting in Q1 2018, the following state agencies will start using the NMLS MSB Call Report: ?Indiana Department of Financial Institutions, Iowa Division of Banking, New York Department of Financial Institutions, Ohio...more
Starting in Q3 2017 (July 1, 2017 to September 20, 2017), the Michigan Department of Insurance and Financial Services is requiring Money Transmitter licensees...more
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
Seventeen state agencies, affecting 22 license types, have currently committed to adopt the NMLS MSB Call report for Q1 2017 reporting. The NMLS MSB Call Report applies to licensees who conduct the following activities: money...more
On March 24 FinCEN issued a second set of the Frequently Asked Questions meant to clarify key questions that have persisted regarding compliance with the Prepaid Access Rule. The FAQs covered five questions....more
On March 11, 2016, FinCEN issued Guidance reminding MSBs and their agents of their respective AML obligations and, most importantly, reminding MSBs that they are responsible for their agents’ activities. The Guidance reminds...more
The Financial Crimes Enforcement Network recently issued two administrative rulings holding that certain virtual currency trading platforms and payment systems were subject to registration as money services businesses....more