News & Analysis as of September 21, 2024

Financial Institutions

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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 -

Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

Wilson Sonsini Goodrich & Rosati on 8/20/2024

Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more

The Shadow Financial System

White & Case LLP on 6/18/2024

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

PA Department of Banking and Securities: Virtual Currency is “Money”

Ballard Spahr LLP on 5/14/2024

On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more

[Webinar] Implications of FinCEN's Notice of Proposed Rulemaking on Virtual Currency Mixers - January 17th, 9:00 am PT

K2 Integrity on 12/21/2023

Join K2 Integrity Global Co-managing Partner and Chief Strategy Officer Juan Zarate and Coinbase Global Head of Financial Crimes Compliance Valerie-Leila Jaber for a discussion of FinCEN’s notice of proposed rulemaking on...more

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on 12/8/2023

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

Sheppard Mullin Richter & Hampton LLP on 12/4/2023

The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

FinCEN to Shed Light on Illicit Use of Virtual Currency Mixing Through Enhanced Record Keeping and Reporting Requirements

Troutman Pepper on 11/29/2023

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) that identifies international convertible virtual currency mixing as a class of...more

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

Foodman CPAs & Advisors on 11/29/2023

El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more

Terrorist Financing FinCEN Red Flags

Foodman CPAs & Advisors on 11/29/2023

On 10/20/23, Terrorist Financing Red Flags were issued by FinCEN to assist financial institutions in identifying funding streams for the terrorist organization Hamas in response to Hamas’s terrorist attack on the people of...more

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

Kelley Drye & Warren LLP on 11/27/2023

On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

Alerta De FinCEN De “Masacre De Cerdos”

Foodman CPAs & Advisors on 11/17/2023

El 8/9/23, FinCEN emitió una alerta sobre una estafa frecuente de inversión en moneda virtual comúnmente conocida como ““masacre de cerdos” ” o “Pig Butchering”. La alerta de FinCEN sobre la “masacre de cerdos” aborda las...more

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

K2 Integrity on 11/14/2023

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

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

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

Eversheds Sutherland (US) LLP on 10/30/2023

On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...more

FinCEN Proposes To Designate Convertible Virtual Currency Mixing as a Primary Money Laundering Concern

Skadden, Arps, Slate, Meagher & Flom LLP on 10/27/2023

The Proposed Rule Aims To Increase Transparency in CVC Mixing - On October 19, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a notice of proposed rulemaking (Proposal)...more

FinCEN’s Pig Butchering Alert

Foodman CPAs & Advisors on 10/26/2023

On 9/8/23, FinCEN issued an alert on a prevalent Virtual Currency Investment Scam commonly known as “Pig Butchering”. FinCEN’s Pig Butchering alert addresses “Pig butchering” scams which resemble the practice of fattening a...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - October 2023 # 4

Troutman Pepper on 10/25/2023

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

FinCEN Issues Alert for Financial Institutions on Red Flags for “Pig Butchering” Schemes

Troutman Pepper on 9/13/2023

On September 8, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) issued an alert warning financial institutions to be vigilant against a prominent virtual currency investment scam called...more

Daily Financial Regulation Update -- Monday, April 24, 2023

Paul Hastings LLP on 4/24/2023

April 21, 2023- Assistant Secretary of the Treasury for Terrorist Financing and Financial Crimes Elizabeth Rosenberg and Deputy Homeland Security Adviser Joshua Geltzer hosted a roundtable at the U.S. Department of the...more

FinCEN Highlights Responsible Crypto Innovation, Warns Service Providers

Sheppard Mullin Richter & Hampton LLP on 6/1/2022

On May 19, Alessio Evangelista, the Associate Director of the Enforcement and Compliance Division of FinCEN, presented at the Chainalaysis Links Conference on the topic of “Intersection of Cryptocurrencies and National...more

Sanctions Against Russia: The Week in Review - April 2022 - 3

K2 Integrity on 4/27/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our regular reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

FinCEN Provides Reminder About BSA Reporting Requirements

Freeman Law on 3/30/2022

FinCEN and Bank Secrecy Act Reporting - On March 7, 2022, the Financial Crime Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury alerted financial institutions “to be vigilant against efforts to...more

FinCEN warns financial institutions to be “vigilant” for Russia sanctions violations

Eversheds Sutherland (US) LLP on 3/21/2022

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more

Sanctions Against Russia: The Week in Review - March 2022

K2 Integrity on 3/18/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

Harris Beach PLLC on 3/15/2022

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

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