News & Analysis as of September 26, 2024

Virtual Currency › BSA/AML

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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 -

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

Ballard Spahr LLP on 11/1/2023

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

FDIC's Annual Risk Review Includes Crypto Risks for First Time

Cadwalader, Wickersham & Taft LLP on 8/21/2023

The Federal Deposit Insurance Corporation (“FDIC”) published its annual Risk Review this past Monday, providing an overview of banking conditions for 2022 through early 2023. The FDIC started providing Risk Reviews to the...more

Crypto platform reaches $100 million settlement to resolve alleged compliance failures

Orrick, Herrington & Sutcliffe LLP on 1/6/2023

On January 4, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of New York virtual currency, anti-money laundering, transaction monitoring, and cybersecurity...more

New York State Department of Financial Services Imposes $30 Million Fine in First Cryptocurrency Enforcement Action

White & Case LLP on 8/15/2022

On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more

New York State Department of Financial Services Publishes First Crypto Industry Consent Order

BakerHostetler on 8/15/2022

On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...more

NY Department of Financial Services Outlines How Blockchain Analytics Should Be Used for Compliance

Skadden, Arps, Slate, Meagher & Flom LLP on 5/18/2022

On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more

2021 Anti-Money Laundering and Sanctions Year in Review

Jones Day on 3/10/2022

2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more

FinCEN Crypto & Ransomware Guidance: Will 2022 Bring More Changes?

Torres Trade Law, PLLC on 1/26/2022

The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...more

GAO Publishes Report on Nexus Between Virtual Currencies and Human and Drug Trafficking Financing

Ballard Spahr LLP on 1/26/2022

The U.S. Government Accountability Office (“GAO”) recently issued a public version of a more detailed and confidential report previously sent to Congress summarizing the GAO’s review of the use of virtual currencies to...more

Tuesday’s Rising Regulatory Chorus On Crypto

Burr & Forman on 9/23/2021

This past Tuesday, September 21, the chorus calling for more regulation over crypto reached a sort of crescendo. The SEC - Earlier, in September 14 testimony before the Senate Banking Committee [1], former CFTC and current...more

FinCEN Announces Anti-Money Laundering Priorities

McDermott Will & Emery on 7/19/2021

The Financial Crimes Enforcement Network (FinCEN) recently issued its government-wide anti-money laundering (AML) and countering the financing of terrorism (CFT) priorities (AML/CFT priorities). FinCEN issued the AML/CFT...more

Congress Tasks GAO to Study the Intersection of Money Laundering and Humanitarian Issues: Human Trafficking and De-Risking

Ballard Spahr LLP on 3/15/2021

Fifth Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) makes major changes to the Bank Secrecy Act (“BSA”) and the U.S....more

SEC Releases 2021 Examination Priorities

Goodwin on 3/8/2021

In this Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations released its 2021 Examination Priorities and issued a risk alert noting that “Digital Asset Securities” entail characteristics and...more

FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

Morgan Lewis on 1/20/2021

Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more

AML Enforcement Is a Key Tool to Combat Cryptocurrency Crimes

Orrick, Herrington & Sutcliffe LLP on 11/13/2020

On October 8, 2020, the U.S. Attorney General’s Cyber-Digital Task Force released its Cryptocurrency Enforcement Framework. The Framework makes clear that, in addition to prosecuting bad actors who use cryptocurrency to...more

The CFTC Begins Policing AML Enforcement

Orrick, Herrington & Sutcliffe LLP on 10/22/2020

Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town. The Commodity Futures Trading Commission recently finished its fiscal year with...more

DOJ Cryptocurrency Enforcement Framework Highlights Risk for Those Engaged in Virtual Asset and Cryptocurrency Activity

Fenwick & West LLP on 10/21/2020

In case it was not already clear, the U.S. Department of Justice recently confirmed that ensuring the use of cryptocurrency “is safe, and does not imperil our public safety or our national security, is vitally important to...more

Bitcoin Is “Money” For Purposes Of D.C. Money Transmission Law, Says Federal Court

Morrison & Foerster LLP on 8/17/2020

A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...more

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

Orrick - On the Chain on 5/28/2020

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

FinCEN Renews Real Estate GTOs

Ballard Spahr LLP on 5/13/2020

As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

Ballard Spahr LLP on 3/5/2020

In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

G20 calls on countries to adopt FATF crypto standards

Hogan Lovells on 2/28/2020

The G20 has urged countries to adopt the Financial Action Task Force (FATF) standards on virtual assets and virtual asset service providers, which were adopted in June last year. ...more

Cryptocurrency and OFAC: Beware of the Sanctions Risks

Orrick - On the Chain on 1/24/2020

A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

Ballard Spahr LLP on 9/20/2019

Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more

Anti-Money Laundering and Sanctions: Trends and Developments Emerging Under the Trump Administration

WilmerHale on 7/29/2019

Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more

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Virtual Currency › BSA/AML

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