News & Analysis as of

Virtual Currency Suspicious Activity Reports (SARs)

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 -
Ballard Spahr LLP

Hamas, Terrorist Financing, and Cryptocurrency

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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

Foodman CPAs & Advisors

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

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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

K2 Integrity

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

K2 Integrity on

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

Ballard Spahr LLP

“Pig Butchering”: FinCEN Issues Alert on Virtual Currency Scam

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On September 8, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released an alert regarding a notorious virtual currency scam called “pig butchering,” because, unfortunately, it resembles the “fattening a hog before...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

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The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Paul Hastings LLP

Top PHive Crypto Enforcement Notes: September Edition

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Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

Freeman Law

FinCEN Provides Reminder About BSA Reporting Requirements

Freeman Law on

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

Harris Beach PLLC

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

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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

Ballard Spahr LLP

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

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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

Eversheds Sutherland (US) LLP

Sanctions 2.0: US Treasury Department announces results of sanctions policy review and OFAC releases compliance guidance for the...

The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Ballard Spahr LLP

FinCEN Reports Spiraling SARs Relating to Ransomware

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On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more

Alston & Bird

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

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On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

Ballard Spahr LLP

FinCEN and CFTC Reach Groundbreaking $100 Million AML Settlement with BitMEX

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Government Alleges Systemic and Deliberate AML Failures - Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring - The Financial Crimes Enforcement Network (“FinCEN”) and...more

Orrick, Herrington & Sutcliffe LLP

Off‐Shore Crypto Exchange to Pay Up to $100 Million to Resolve Enforcement Action with U.S. Regulators

The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

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The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Perkins Coie

Blockchain Week in Review - January 2021

Perkins Coie on

Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more

King & Spalding

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

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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

Ballard Spahr LLP

To Fight Terrorism, FinCEN and Federal Reserve Board Request Comment on Proposed Major Expansion of Recordkeeping and Travel Rules...

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Proposed Change Would Expand BSA Definition of “Money” to Include Virtual Currency - The Financial Crimes Enforcement Network (“FinCEN”) and the Federal Reserve Board (“Board”) have requested comment on an important...more

Jones Day

FinCEN Issues Guidance on Ransomware Attacks

Jones Day on

The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more

Orrick, Herrington & Sutcliffe LLP

The CFTC Begins Policing AML Enforcement

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

Orrick - On the Chain

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

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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

Robins Kaplan LLP

Financial Daily Dose 12.12.2019 | Top Story: Fed Holds Rates Steady And Looks to Stay There

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As expected, the Fed kept interest rates unchanged on Wednesday while also signaling that “they would wait to see how the economy fared before making another move”....more

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