News & Analysis as of

Convertible Virtual Currencies (CVCs) Bank Secrecy Act

Sheppard Mullin Richter & Hampton LLP

FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks

On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity involving convertible virtual currency (CVC) kiosks. The notice cites...more

BakerHostetler

Weekly Blockchain Blog - August 2024 #4

BakerHostetler on

Financial Firms Announce Crypto Initiatives, Stablecoin Growth Continues - A major U.S. crypto investment company recently announced the launch of its Avalanche Trust, which “offers investors the opportunity to gain...more

Morrison & Foerster LLP

All Your Sale Are Belong to Us - Mitigating IP and Payments Risk in In-Game Economies

The digital age has ushered in innovative forms of entertainment and commerce, including through the development of in-game economies. In recent years, the digital landscape of gaming has expanded beyond mere entertainment,...more

Paul Hastings LLP

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

Paul Hastings LLP on

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

Ballard Spahr LLP

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

Ballard Spahr LLP on

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

Ballard Spahr LLP

Russian Sanctions: FinCEN Provides Red Flags for Potential Evasion Attempts

Ballard Spahr LLP on

On March 7, the Financial Crimes Enforcement Network (FinCEN) issued an alert “advising all financial institutions to be vigilant against potential efforts to evade the expansive sanctions and other U.S.-imposed restrictions...more

Perkins Coie

Recent Developments in US Sanctions and Export Controls Targeting Russia

Perkins Coie on

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

McGuireWoods LLP

FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual...

McGuireWoods LLP on

The Financial Crimes Enforcement Network (FinCEN) has issued an alert encouraging all financial institutions to be “vigilant” against efforts by their customers to evade recent sanctions and other restrictions imposed by the...more

K2 Integrity

Proposal to Revise Recordkeeping and Travel Rule Requirements Poses Implementation Challenges for FIs and VASPs

K2 Integrity on

The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements,...more

Morrison & Foerster LLP

FinCEN Seeks To Expand Scope Of Information Collection And Recordkeeping Requirements For Money Transmitters And Other Financial...

Morrison & Foerster LLP on

A new proposed rulemaking (the “NPRM”) would lower the current $3,000 threshold for the applicability of the Bank Secrecy Act (“BSA”) Recordkeeping Rule and Travel Rule to $250 for covered funds transfers that begin or end...more

Ballard Spahr LLP

FinCEN Advisory Highlights Money Laundering Risks Related to Fentanyl Trafficking

Ballard Spahr LLP on

On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal...more

Katten Muchin Rosenman LLP

FinCEN Publishes Guidance Pertaining to Certain Business Models Involving Convertible Virtual Currencies

On May 9, the Financial Crimes Enforcement Network of the US Department of the Treasury (FinCEN) issued guidance relating to how its regulations apply to certain businesses that transact in "convertible virtual currencies"...more

Jones Day

Financial Crimes Enforcement Network Consolidates Guidance on Virtual Currencies

Jones Day on

The Situation: The Financial Crimes Enforcement Network ("FinCEN") released interpretive guidance concerning the application of the Bank Secrecy Act ("BSA") and the anti-money laundering ("AML") regulations to certain...more

Ballard Spahr LLP

New FinCEN Cryptocurrency Guidance Provides Comprehensive Overview of BSA Application to Crypto Businesses

Ballard Spahr LLP on

Some Answers — Producing Even More Questions - On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) published a comprehensive “interpretive guidance” (the “Guidance”) to “remind” businesses and individuals...more

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