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Ankura

Crafting Effective Public Comments: How and Why You Should Participate in the Rulemaking Process

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When regulators propose a new rule, financial institutions can often find themselves pushed into a reactionary position, left to deal with consequences that rule makers may not have foreseen. Once a rule hits the books, legal...more

Ankura

Exam Time: Understanding Exam Ratings

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It is inevitable that your Money Service Business (MSB) will eventually receive a much-anticipated (or in some instances, much-dreaded) Exam Engagement letter from one or more states. MSBs licensed in 40 or more states meet...more

K&L Gates LLP

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

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On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Torres Trade Law, PLLC

FinCEN Crypto & Ransomware Guidance: Will 2022 Bring More Changes?

Torres Trade Law, PLLC on

The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...more

Ballard Spahr LLP

Joint Statement on Digital Assets Highlights AML Regulatory Overlap

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Leaders of FinCEN, CFTC and SEC Attempt an Intricate Dance of Competing Oversight of Virtual Currency - On October 11, the leaders of the Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading...more

Perkins Coie

FinCEN Is Watching ICOs for BSA Violations

Perkins Coie on

In a recently published letter to the Senate Finance Committee, FinCEN confirmed that when an ICO token is a “convertible virtual currency,” administrators or exchangers of the token would be “money transmitters” under...more

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