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Money Services Business Financial Services Industry FinCEN

Ballard Spahr LLP

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

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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

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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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

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Issues GTO Imposing New Obligations on Southwest Border MSBs

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

Troutman Pepper Locke

Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast

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In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory discuss the latest FinCEN and OFAC guidance on virtual currency transactions, specifically tailored for companies in the payments industry. They...more

Ballard Spahr LLP

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

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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

Wilson Sonsini Goodrich & Rosati

Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

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

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is “Money”

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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

WilmerHale

“Decentralized Finance (DeFi),” Fintech, Regtech, and the Financial Services Industry (Ch. 8A)

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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

Hudson Cook, LLP

Florida Regulator Clarifies Money Transmitter Licensing Exemptions (or lack thereof)

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Among the many state licenses that can impact financial services companies, money transmitter licensing can be among the harder to figure out. In addition to uncertainties about digital currency and developing technologies,...more

McGlinchey Stafford

Podcast: Deep Dive Into Payments: Impacts of Money Transmission Laws [More with McGlinchey, Ep. 59]

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The next item in McGlinchey's Deep Dive into Payments Series is a podcast on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money...more

McGlinchey Stafford

Deep Dive Into Payments: Impacts of Money Transmission Laws

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The next item in McGlinchey’s Deep Dive into Payments Series is on money transmission by attorneys Jeff Barringer, Amy Greenwood-Field, and Aaron Kouhoupt. Their discussion centers around the impacts of money transmission...more

Orrick, Herrington & Sutcliffe LLP

Senators exploring bank’s dealings with collapsed crypto exchange

On January 30, Senators Elizabeth Warren (D-MA), John Kennedy (R-LA), and Roger Marshall (R-KS) sent a follow-up letter to a California-based bank asking for additional responses to questions related to the bank’s...more

Cadwalader, Wickersham & Taft LLP

Regulators Sharpen Focus on Anti-Money Laundering Expectations for Crypto Industry

U.S. regulators are signaling heightened expectations for anti-money laundering compliance within the crypto industry. Although FinCEN issued guidance in 2013 interpreting virtual currency “administrators” and “exchanges” as...more

Torres Trade Law, PLLC

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

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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

Morgan Lewis

FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

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Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more

Ballard Spahr LLP

FinCEN Director Blanco Urges Collaboration Across Virtual Currency Industry to Comply with Travel Rule

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Kenneth Blanco, Director of the Financial Crimes Enforcement Network (“FinCEN”), recently provided remarks about FinCEN’s “Travel Rule” at the first truly-virtual Consensus Blockchain Conference. ...more

Ballard Spahr LLP

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

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Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more

A&O Shearman

US Authority Settles Charges Against Peer-to-Peer Virtual Currency Exchanger for Violating Registration and AML Requirements

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The U.S. Treasury Department's Financial Crimes Enforcement Network has announced that it has settled charges against Eric Powers, a peer-to-peer exchanger of convertible virtual currency, for violating the registration,...more

Morgan Lewis

FinCEN Issues Guidance on Cryptos

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The Financial Crimes Enforcement Network (FinCEN) recently issued guidance consolidating current FinCEN regulations, rulings, and guidance about cryptocurrencies and money services businesses (MSBs) under the Bank Secrecy Act...more

Burr & Forman

FinCEN Announces Civil Monetary Penalty for Virtual Currency Exchanger

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On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more

Foodman CPAs & Advisors

Who monitors digital currency wallets?

Investors in Virtual Currency (VC) utilize the services of on-line “secure” platforms for buying, selling, transferring, and storing VC. The providers of these services are known as web-wallets (Coinbase is an example). ...more

Ballard Spahr LLP

Beyond Best Practices: Regulatory Compliance Now a Necessity in the Cryptocurrency Sector

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As the value of bitcoin continues to soar (USD:BTC this past weekend exceeded $19,000.00:1), we thought that now would be a good time to emphasize the need to ensure regulatory compliance with the many federal and state AML...more

Ballard Spahr LLP

FinCEN Takes First Action Against Foreign-Located MSB—“The Virtual Currency Exchange of Choice for Criminals”—For Willfully...

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On July 26, FinCEN, in coordination with the U.S. Attorney’s Office for the Northern District of California (“NDCA USAO”), assessed a $110,003,314 civil money penalty against BTC-e a/k/a Canton Business Corporation (“BTC-e”)...more

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