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Uniform Commercial Code (UCC) FinCEN

Saul Ewing LLP

Digital Assets and the UCC: Article 12 Legislative Updates

Saul Ewing LLP on

New amendments to the Uniform Commercial Code (UCC) have been proposed which relate to transactions involving cryptocurrencies, digital assets, and blockchain technology. The amendments add a new Article 12 to the UCC, which...more

King & Spalding

State Attorneys General Poised to Elevate Regulatory Scrutiny of Digital Asset Businesses

King & Spalding on

The Attorney General Alliance (“AGA”) recently issued a collaborative White Paper that signals heightened scrutiny of digital asset businesses by state Attorneys General in coming years. Recognizing that it is “no longer...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

King & Spalding

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

King & Spalding on

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

Sullivan & Worcester

U.S. Senate Report Takes a Swing at Money Laundering in the Art Market But Strikes Out on Substance

Sullivan & Worcester on

A recent report by the U.S. Senate Permanent Subcommittee on Investigations (headlined by Chairman Senator Rob Portman, Republican of Ohio, and Ranking Member Tom Carper, Democrat of Delaware) has drawn widespread attention...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2019)

Hudson Cook, LLP on

This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more

Perkins Coie

Treatment of Bitcoin Under U.S. Property Law

Perkins Coie on

In this white paper, we analyze the treatment of bitcoin under applicable U.S. property law. We conclude that property interests should exist in bitcoin under such law, and that multiple sources of persuasive authority...more

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