Guidepost in Motion: Banking on Crypto Continued
On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more
Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...more
The extension of the Financial Action Task Force (FATF) ‘Travel Rule’ to ‘Virtual Asset Service Providers’ (VAPSs) is emblematic of the continued and growing push to bring crypto businesses into the mainstream of financial...more
The “Travel Rule” is a Bank Secrecy Act (BSA) rule [31 CFR 103.33(g)] that requires financial institutions to pass certain information on to the next financial institution, in certain funds transmittals involving more than...more
El “Travel Rule” es una regla de la Ley de Secreto Bancario (“BSA”) regla [31 CFR 103.33(g)] y requiere que todas las instituciones financieras transmitan cierta información a la siguiente institución financiera, en ciertas...more
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
The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements,...more
VIDEO: Cryptocurrency - Legitimate Uses and Potential Issues - Following the recent publication of the U.S. Attorney General's cryptocurrency enforcement framework, Spilman attorneys Corey Bonasso and Nick Mooney discuss...more
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
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 October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more
On May 13, 2020, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco delivered remarks to the Consensus Blockchain Conference regarding the agency’s recent observations in connection with virtual...more
Kenneth Blanco, Director of the Financial Crimes Enforcement Network (“FinCEN”), recently provided remarks about FinCEN’s “Travel Rule” at the first truly-virtual Consensus Blockchain Conference. ...more
The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more