Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast
Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros – The Payments Law Podcast
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
We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA...more
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
In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more
The Anti-Terrorism Act (ATA) created a federal cause of action enabling U.S. nationals injured by reason of an "act of international terrorism" to sue those allegedly responsible for their injuries; it was later amended to...more
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
On March 14, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in the Federal Register that will impose new obligations on many money services...more
On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more
We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more
On March 11, 2025, the United States Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring certain money service businesses (MSBs) in...more
Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more
Le 5 juillet 2024, le ministère des Finances du Canada (le « ministère des Finances ») a publié des projets de règlement en application de la Loi sur le recyclage des produits de la criminalité et le financement des activités...more
On July 5, 2024, the Department of Finance released draft regulations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), which, among other things, implement some of the changes outlined in...more
On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more
Decentralized Finance (DeFi) is an umbrella term used to describe financial services provided outside of the traditional markets, that rely on blockchain technologies to create innovative products instead of relying on...more
• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more
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
On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more
Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more
Regulators are increasingly taking enforcement action against crypto asset industry participants for violating anti-money laundering (AML) and sanctions laws. Regulators are concerned about the illicit use of crypto...more
The Dec. 14, 2022, introduction of the Digital Asset Anti-Money Laundering Act by Sens. Elizabeth Warren, D-Mass., and Roger Marshall, R-Kan., marks the end of a tumultuous year in the cryptocurrency industry that saw a...more
The U.S. Treasury Department recently released its “first of its kind” strategy to address financial institution de-risking. Mandated by the Anti-Money Laundering Act of 2020, the 2023 De-Risking Strategy examines customer...more
Le 21 avril 2023, le gouvernement du Canada a déposé un avis de motion de voies et moyens visant à mettre en œuvre certaines dispositions du budget fédéral de 2023 (le « Budget 2023 »). Comme nous l’avons mentionné plus tôt...more
On April 21, 2023, the Canadian government introduced the Notice of Ways and Means Motion to implement certain provisions of the 2023 federal budget. As we noted earlier this month, certain changes were proposed to the...more