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Virtual Currency › Advisory Opinions

Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender... more +
Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency.    less -
WilmerHale

OFAC Imposes New Sanctions to Thwart Ransomware

WilmerHale on

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

Latham & Watkins LLP

CFTC Adds Another Building Block to its Digital Asset Framework

Latham & Watkins LLP on

The CFTC issues stringent guidelines for FCMs seeking to custody digital assets in connection with physically delivered futures contracts or swaps. The US Commodity Futures Trading Commission’s (CFTC’s) Division of Swap...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Releases Advisory for Banks, MSBs on Potentially Illicit Transactions with Iran

Akin Gump Strauss Hauer & Feld LLP on

• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...more

Goodwin

FinCEN Issues Five Advisory Rulings Concerning the Application of the Bank Secrecy Act’s Definition of “Money Transmitter” to...

Goodwin on

The Financial Crimes Enforcement Network (“FinCEN”) published five administrative rulings (collectively, the “Rulings,” and each a “Ruling”) concerning the applicability of certain exemptions from money transmitter status to...more

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