News & Analysis as of

Risk Assessment Virtual Currency

Hudson Cook, LLP

"OVER THE LINE!"  Where Banking and Gaming Intersect, the CFPB Has Something to Say.

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The line between virtual and reality is getting thinner. Gamers pay gaming companies real currency for virtual in-game currency to buy skins, create the world they want to live in (virtually), or purchase loot that aid in...more

K2 Integrity

NYDFS Issues Updated And Stricter Virtual Currency Listing Guidance – New Policy Updates Due For Approval By January 31, 2024

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Following a two-month public consultation period, on 15 November 2023 the New York State Department of Financial Services (NYDFS) published its new Virtual Currency Listing Guidance (the Guidance), in accordance with virtual...more

K2 Integrity

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

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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

Orrick, Herrington & Sutcliffe LLP

Top 5 Takeaways from NYDFS $1.2 Million Fine in Cybersecurity Case

On May 1, the New York Department of Financial Services (“NYDFS” or “Department”) and a trading platform entered into a consent order to resolve deficiencies identified during examinations conducted in 2018 and 2020. The...more

Proskauer - Blockchain and the Law

New York Department of Financial Services Issues Guidance on Cryptoasset Custody in Wake of Recent High-Profile Bankruptcies

Demand for virtual currency services, including custody services, has soared in the past several years. Like their counterparts in traditional finance, these custodians are stewards of retail and institutional customer funds...more

Foley & Lardner LLP

Top Trends in Digital Assets for 2022

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It's no secret that cryptocurrency markets and the larger digital assets economy have been roiled by recent instability, resulting in discussions about how regulatory initiatives, rising inflationary pressure, and public...more

Perkins Coie

Blockchain Week in Review - March 2022

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...Treasury Releases National Risk Assessments - The U.S. Department of the Treasury (Treasury) issued the 2022 National Risk Assessments (NRAs) on (1) money laundering, (2) terrorist financing, and (3) proliferation...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

Faegre Drinker Biddle & Reath LLP

OFAC Issues Sanctions Compliance Guidance for Virtual Currencies

In October, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new guidance for the virtual currency industry focusing on compliance with the financial industry’s obligations...more

McDermott Will & Emery

OFAC Reaffirms Focus on Virtual Currency with Sanctions Law Guidance

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On October 15, 2021, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) announced updated guidance for virtual currency companies in meeting their obligations under US sanctions laws. On the same day,...more

Bracewell LLP

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

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In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

Kelley Drye & Warren LLP

OFAC Puts Virtual Currency Industry on Notice, Highlights Best Practices for Digital Commerce

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On October 15, 2021, the Office of Foreign Assets Control (OFAC) issued an advisory providing sanctions compliance guidance for the virtual currency industry (Guidance). The Guidance follows a series of recent enforcement...more

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

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Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Fenwick & West LLP

Guidance for the Virtual Currency Industry; 2021 Sanctions Review Shows Increasing Focus on Digital Transactions

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued tailored sanctions compliance guidance for those operating in the virtual currency industry, including technology...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

Rosenberg Martin Greenberg LLP

Bitcoin, the IRS, and the Love that was Lost

We have all heard the stories. Romeo and Juliet, Cleopatra and Mark Antony, and my personal favorite, Illsa Lund and Rick Blaine. Everyone loves a great love story.  A developing romance leading to an emotionally pleasing and...more

Hogan Lovells

UK FCA becomes AML/CFT crypto supervisor

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The UK Financial Conduct Authority (FCA) has become the anti-money laundering and countering the financing of terrorism (AML/CFT) supervisor for some types of cryptoasset businesses. These will need to meet certain...more

White & Case LLP

NYDFS Requires LIBOR Transition Plans by Early February

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On December 23, 2019, the New York Department of Financial Services (NYDFS) issued an Industry Letter instructing each institution it regulates, including banks and licensed Fintechs, to make submissions describing the...more

A&O Shearman

UK Implements EU’s Fifth Anti-Money Laundering Directive

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U.K. revisions to its anti-money laundering and counter terrorist financing regime come into force on 10 January 2020. The U.K.’s revisions implement the European Union’s Fifth Anti-Money Laundering Directive, commonly...more

Dechert LLP

Financial Crimes Enforcement Network, Treasury Department Affirm Regulatory Regime for Convertible Virtual Currencies

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more

Ballard Spahr LLP

Update: Government Enforcement in the Cryptocurrency Space

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First Post in a Two-Part Series - Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more

Dechert LLP

Crypto Never Sleeps: Vigilance Required in OFAC Sanctions Compliance Involving Virtual Currencies and Digital Assets

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For years, regulators around the world have struggled with whether and how to police the offering and exchange of digital assets (including virtual currencies such as Bitcoin). In the United States, such efforts were stymied...more

The Volkov Law Group

Cryptocurrency Compliance: The Importance of Internal Investigations

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For those still new to the sector, Coinbase has established itself as one of (if not the) most prominent cryptocurrency exchanges operating in the U.S. Coinbase, to the delight of compliance officers everywhere, has been...more

Sheppard Mullin Richter & Hampton LLP

New York’s AG Enters the Cryptocurrency Ring as Federal, State Authorities Find Regulatory Footing

On April 17, 2018, the New York State Attorney General (“NYAG”) sent a “Virtual Markets Integrity Initiative Questionnaire” to 13 companies operating virtual currency trading platforms. The questionnaire consists of 34...more

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