News & Analysis as of

Patriot Act Money Services Business

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Morrison & Foerster LLP

FinCEN Targets Convertible Virtual Currency Mixing to Combat Terrorist Financing and Other Illegal Transactions

Morrison & Foerster LLP on

Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more

White & Case LLP

FinCEN’s proposed regulation of virtual assets

White & Case LLP on

A controversial proposed rule from the Financial Crimes Enforcement Network would bring bank-like regulation of virtual asset transactions, including the first broadly-applied AML reporting requirement in at least two...more

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