News & Analysis as of September 8, 2025

Money Laundering

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

Ballard Spahr LLP on 8/27/2025

On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more

Treasury Issues Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets

Troutman Pepper Locke on 8/25/2025

On August 18, the U.S. Department of the Treasury issued a Request for Comment, inviting interested members of the public to provide input on innovative methods to detect and mitigate illicit finance risks involving digital...more

The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

Mayer Brown on 8/15/2025

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

FinCEN Seeks Enhanced Oversight of Crypto Mixing

Latham & Watkins LLP on 11/3/2023

A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors. On October 19, 2023, the US Department of the Treasury’s Financial Crimes...more

Blockchain Game Developers and FinCEN: When are State Money Transmission Laws Applicable?

Sheppard Mullin Richter & Hampton LLP on 10/4/2022

The rising prevalence of crypto and virtual currencies has invited the scrutiny of several regulatory bodies who continue to grapple with the unique challenges posed by blockchain technology, FinCEN being one prime example....more

Headed to the Metaverse? Be "The One" to Minimize Money Laundering Risk

Wilson Sonsini Goodrich & Rosati on 7/15/2022

Wilson Sonsini provides extensive and cutting-edge legal services for innovators, technology pioneers, and disruptors. As part of our focus on emerging technologies, our attorneys are publishing a series on applying and...more

State Attorneys General Poised to Elevate Regulatory Scrutiny of Digital Asset Businesses

King & Spalding on 7/13/2022

The Attorney General Alliance (“AGA”) recently issued a collaborative White Paper that signals heightened scrutiny of digital asset businesses by state Attorneys General in coming years. Recognizing that it is “no longer...more

Money Laundering and High-Value Art: Treasury’s Study Discusses Financial Crimes and NFTs

Sheppard Mullin Richter & Hampton LLP on 3/3/2022

With the advent of blockchain technology, vendors are increasingly accepting payments of goods, including artwork, with digital currency. The decentralized nature of digital currency makes it attractive for a lot of reasons,...more

Are You Ready for Web3.0 and the Legal Issues it Will Bring?

Sheppard Mullin Richter & Hampton LLP on 2/28/2022

Blockchain is one of the most significant new technologies since the internet. It has ushered in what has been referred to as Web3.0. Some of the most popular applications of this technology include NFTs and metaverses. ...more

Blockchain Week in Review - September 2020 #2

Perkins Coie on 9/23/2020

U.S. Developments - Federal and State Regulatory Developments - U.S. Department of Homeland Security Issues Challenge for Development of Trusted User Interface for Digital Wallets - The U.S. Department of Homeland Security...more

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

Katten Muchin Rosenman LLP on 6/26/2019

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

New FinCEN Cryptocurrency Guidance Clarifies Applicability of Anti-Money Laundering Regulations to Virtual Currency Business...

Robinson+Cole Data Privacy + Security Insider on 5/24/2019

The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more

Manipulation Detected on ‘DEXes,’ Regulations Develop, Industry Initiatives Advance, Hacks, Money Laundering and Enforcement...

BakerHostetler on 4/19/2019

Academics Detect Manipulation on ‘DEXes’ as Cryptocurrency Trading Expands - A recent academic paper by researchers at Cornell Tech and other academic institutions describes rampant trading manipulation on decentralized...more

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