News & Analysis as of August 12, 2025

Suspicious Activity Reports (SARs)

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The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -

FinCEN Addresses Increased Fraud Involving Convertible Virtual Currency Kiosks

Perkins Coie on 8/11/2025

Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more

Department of Justice Settles with Las Vegas Casino for $130 Million

Pillsbury Winthrop Shaw Pittman LLP on 9/23/2024

The settlement is the latest example of the agency’s enhanced criminal enforcement of money transmitting business and international money-laundering laws. The recent settlement is significant both in terms of its amount...more

FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing

Ballard Spahr LLP on 6/11/2024

The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release...more

KuCoin and Founders Charged with Operating Illegally as Money Transmitter and Futures Commission Merchant

Ballard Spahr LLP on 4/5/2024

Last week, the United States Attorney’s Office for the Southern District of New York unsealed an indictment against global cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang, for allegedly conspiring...more

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

Ballard Spahr LLP on 2/5/2024

The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

Ballard Spahr LLP on 11/27/2023

As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more

FinCEN’s Mixer 311 Has Immediate Impacts for U.S. Financial Institutions and De-Fi Protocols

Paul Hastings LLP on 11/3/2023

On October 19, FinCEN announced its determination that transactions with foreign operating crypto-mixers, a service that obfuscates the source and destination of transactions on a public blockchain, are of “Primary Money...more

SEC’s 2024 Examination Priorities: Cryptocurrency, Emerging Tech, and AML

Troutman Pepper Locke on 10/31/2023

As reported in more detail on our Regulatory Oversight blog, the Securities and Exchange Commission’s Division of Examinations recently released its 2024 Examination Priorities report. The report underscores the SEC’s intent...more

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

Ballard Spahr LLP on 9/14/2023

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

Top PHive Crypto Enforcement Notes: January Edition

Paul Hastings LLP on 1/13/2023

Happy New Year! While the holidays hopefully provided a chance to rest and recharge, things have not slowed down in the world of digital asset enforcement. We see a growing dedication of resources by government law...more

New York Sends Clear Message Crypto Exchanges and Banks Must Meet AML Obligations

Harris Beach Murtha PLLC on 1/10/2023

New York’s Department of Financial Services (“DFS”) recently announced a $100 million settlement with Coinbase, Inc., one of the world’s largest cryptocurrency exchanges, for Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”)...more

Potential BSA/AML Roadmap – Crypto Exchange Bittrex Enforcement Actions

Harris Beach Murtha PLLC on 11/17/2022

The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) settled enforcement actions with Washington state-based Bittrex. In the two settlements, Bittrex...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on 11/16/2022

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

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

Ballard Spahr LLP on 10/21/2022

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

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

Venable LLP on 10/14/2022

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

Responding to the Increased Global Risk of Financial Crimes

Ankura on 8/12/2022

Ankura's Nova O sits down with Mark McGrath, Ayana Murphy, and Elif Cinar to discuss the current anti-money laundering (AML) landscape in the latest Q&A with our Ankura experts. Learn more about responding to the increased...more

BitMEX Co-Founder and Owner Settles with CFTC and Now Faces Criminal Sentencing

Ballard Spahr LLP on 5/16/2022

The legal saga involving the civil and criminal cases against the entity and former individual owners of the Bitcoin Mercantile Exchange, or BitMEX—a large and well-known online trading platform dealing in futures contracts...more

Cryptocurrency Exchange Founders Plead Guilty to Bank Secrecy Act Violations

Faegre Drinker Biddle & Reath LLP on 3/4/2022

On February 24, 2022, two of three founders of an off-shore cryptocurrency derivatives exchange, the Bitcoin Mercantile Exchange or “BitMEX,” pled guilty to violating the Bank Secrecy Act (BSA) by failing to maintain an...more

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

Ballard Spahr LLP on 8/25/2021

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

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

Orrick, Herrington & Sutcliffe LLP on 8/20/2021

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

Scared Of Your Clients’ Involvement With Cryptocurrency?

McGlinchey Stafford on 5/28/2021

Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more

DOJ Activity on Cryptocurrency: A Six-Month Review

Kelley Drye & Warren LLP on 3/24/2021

The U.S. Department of Justice (“DOJ”) has focused on cryptocurrency in the last six months, while consumer interest hits all-time highs. The cryptocurrency market is not unlike the cannabis market from several years...more

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

King & Spalding on 11/5/2020

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

CFTC and DOJ Charge BitMEX and Executives With Illegally Trading in Digital Assets and Ignoring BSA/AML Requirements

Ballard Spahr LLP on 10/13/2020

Incorporating in the Seychelles but Allegedly Operating in the U.S. Spells Trouble for Company and its Founders - The Bitcoin Mercantile Exchange, or BitMEX, is a large and well-known online trading platform dealing in...more

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on 2/13/2020

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

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