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Recordkeeping Requirements Virtual Currency

White & Case LLP

The Shadow Financial System

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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

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

Ballard Spahr LLP

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

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On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...more

Shipkevich PLLC

New York Issues New Guidance on Crypto Currency Custodial Structures

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On January 23, 2023, New York Department of Financial Services (DFS) released regulatory guidance to better protect customers in the event of virtual currency insolvency. The guidance is not binding, but rather persuasive...more

McGlinchey Stafford

The Wait is Over: Louisiana Proposes Virtual Currency Business Rules

McGlinchey Stafford on

The Louisiana Virtual Currency Business Act (Act), which requires virtual currency businesses to hold a license became effective on August 1, 2020. At that time the Louisiana Office of Financial Institutions (OFI) was tasked...more

Alston & Bird

Investment Management, Trading & Markets Updates – December 2021

Alston & Bird on

NFA Adds Virtual Currency and Micro Contract Questions to Annual Questionnaire On December 6, 2021, the National Futures Association (NFA) released Notice I-21-42 to notify NFA members that new questions had been added to the...more

McDermott Will & Emery

Special Report - A Primer on Charitable Contributions of Virtual Currency

McDermott Will & Emery on

The explosive growth in virtual currency (also referred to as cryptocurrency, digital assets, tokens and digital currency) is evidence of increasing popularity and acceptance of it as a new investment asset class. With the...more

King & Spalding

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

Latham & Watkins LLP

FinCEN Looks to Rein In Cryptocurrency Transactions

Latham & Watkins LLP on

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

White & Case LLP

FinCEN’s proposed regulation of virtual assets

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A controversial proposed rule from the Financial Crimes Enforcement Network would bring bank-like regulation of virtual asset transactions, including the first broadly-applied AML reporting requirement in at least two...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping, verification, and reporting requirements for transactions involving virtual currency and...

On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to establish new requirements for convertible virtual currency (CVC) and legal tender digital asset (LTDA)...more

Troutman Pepper

FinCEN and Federal Reserve Board Request Comments on Expansion of Recordkeeping and Travel Rules

Troutman Pepper on

The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board (referred to as “the Agencies”) are soliciting comments on or by November 27, 2020, on a proposed rule that would significantly expand the...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Guidance Regarding Virtual Currency Transactions

On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more

Sheppard Mullin Richter & Hampton LLP

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Updates Guidance on Crypto

FinCEN has issued 2 new guidance documents addressing cryptocurrency and other convertible virtual currency (CVC). The guidance does not establish any new regulatory expectations. Rather, it consolidates current FinCEN...more

Blake, Cassels & Graydon LLP

The Good, the Bad and the Ugly: Revised Regulations to PCMLTFA

The wait is over. On June 9, 2018, the Department of Finance (Department) released the long-awaited amendments to the regulations to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (Revised...more

Morrison & Foerster LLP

The CSBS Finalizes Model Framework for Virtual Currencies

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

Goodwin

Financial Services Weekly News - September 2015 #3

Goodwin on

Regulatory Developments: CFTC Grants Temporary Registration as SEF to LedgerX Bitcoin Options Exchange and Clearing House - On Sept. 10 the CFTC announced that it had issued an Order of Temporary Registration as a...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - Volume IX, Issue 44

In this issue: - SEC Sanctions 10 Companies for Disclosure Failures Surrounding Financing Deals and Stock Dilution - Delaware Court of Chancery Rejects Entire Fairness Review in Absence of Conflicted Transaction...more

Proskauer - New Media & Technology

FinCEN Releases Two Rulings Classifying a Bitcoin Payment System and Virtual Currency Trading Platform as MSBs

In its opening salvo bringing bitcoin under the watchful eye of the federal government, the Financial Crimes Enforcement Network (FinCEN) issued a Guidance (FIN-2013-G001) in March 2013 clarifying that anti-money laundering...more

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