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United States: The Continuing Shift to Modern Money Transmission Laws

Within the past two months, three states have adopted the Money Transmission Modernization Act (MTMA). The governors of Virginia, Mississippi, and most recently Colorado, signed bills that implement the MTMA, and two other...more

New York (More) Open for (Crypto) Business: NYDFS Proposes Important Changes to the BitLicense

Since finalizing the “BitLicense” regulatory regime in June 2015, the New York Department of Financial Services (NYDFS) has granted only 25 licenses. This underscores how the BitLicense regulatory framework has been a barrier...more

When Does “Actual Delivery” of a Purchased Cryptocurrency Occur? U.S. Ninth Circuit Court of Appeals Sheds Some Light

Back in 2018, four different courts in the U.S. held that cryptocurrencies were commodities. This did not cause a huge ripple in the cryptocurrency community because the Commodity Exchange Act does not apply to retail...more

Trouble in Paradise: Florida Court Rules that Selling Bitcoin is Money Transmission

The growing popularity of virtual currency over the last several years has raised a host of legislative and regulatory issues. A key question is whether and how a state’s money transmitter law applies to activities involving...more

Understanding the Effect of Wyoming’s Blockchain and Cryptocurrency Legislation

March was a busy month in the blockchain and cryptocurrency space for the Wyoming state government. The legislature passed, and the governor signed, five bills that many in the industry view as favorable to blockchain and...more

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

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