News & Analysis as of September 3, 2025

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

FinCEN’s Focus on Cryptocurrency Kiosks and Financial Crime

Ballard Spahr LLP on 8/26/2025

On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also...more

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on 12/8/2023

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Proskauer - Blockchain and the Law on 10/28/2021

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on 7/7/2021

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Global Payments Newsletter, June 2021

Hogan Lovells on 6/16/2021

Key developments of interest over the last month include: Hong Kong: FSTB publishes consultation conclusions on virtual asset services providers licensing regime Europe: European Commission publishes proposal for Regulation...more

Proposed Rules for Transactions with Unhosted Virtual Currency Wallets

K2 Integrity on 1/6/2021

On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury announced highly anticipated and controversial new proposed requirements designed to mitigate illicit finance risks...more

Bitcoin “Mixer” That Anonymizes Transactions Shaken With $60 Million Penalty From FinCEN

Vinson & Elkins LLP on 11/5/2020

The Financial Crimes Enforcement Network (“FinCEN”) recently hit the founder and primary operator of both Helix and Coin Ninja with a $60 million civil monetary penalty. These companies served as “mixers” or “tumblers” for...more

Cryptocurrency 101 – DOJ’s New Cryptocurrency Enforcement Framework Provides Guidance And Promises Of Heightened Scrutiny Of...

Vinson & Elkins LLP on 10/22/2020

On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more

Blockchain Week in Review - June 2020 #2

Perkins Coie on 7/6/2020

US Regulatory Developments - New York’s Financial Services Regulator Announces New Virtual Currency Initiatives - It has been five years since the New York Department of Financial Services (the NYDFS) issued the...more

Blockchain Week in Review - January 2020 #2

Perkins Coie on 1/24/2020

U.S. Developments - U.S. Regulatory Developments - Bill Addressing Tax Treatment of Crypto Transactions Introduced to the House - On January 16, 2020, Congresswoman Suzan DelBene (WA) and Congressman David Schweikert...more

UK FCA becomes AML/CFT crypto supervisor

Hogan Lovells on 1/21/2020

The UK Financial Conduct Authority (FCA) has become the anti-money laundering and countering the financing of terrorism (AML/CFT) supervisor for some types of cryptoasset businesses. These will need to meet certain...more

AMF Establishes New Legal Framework for Digital Asset Service Providers in France

Jones Day on 1/2/2020

The Situation: Following the enactment earlier in 2019 of new French legislation to regulate activities related to digital assets (including cryptocurrency but excluding tokenized securities), final regulatory provisions were...more

Blockchain Week in Review - October 2019

Perkins Coie on 10/18/2019

U.S. Developments - U.S. Federal Regulatory Developments - CFTC, FinCEN, and SEC Leaders Release a Join Statement on Digital Assets - On October 11, 2019, the heads of the Commodity Futures Trading Commission (“CFTC”),...more

Blockchain Week in Review - October 2018 #3

Perkins Coie on 11/2/2018

FATF Issues Virtual Currency Guidance - On October 19, the Financial Action Task Force (“FATF”) published the outcomes of its Plenary meeting. Included in the outcomes of the meeting were new recommendations related to the...more

FinCEN Releases Advisory for Banks, MSBs on Potentially Illicit Transactions with Iran

Akin Gump Strauss Hauer & Feld LLP on 10/23/2018

• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...more

Virtual Currencies: International Actions and Regulations

Perkins Coie on 10/5/2015

This chart is provided by Perkins Coie LLP’s Decentralized Virtual Currency industry practice group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does...more

The Empire State Strikes Back: New York Proposes Rules for Virtual Currency

BakerHostetler on 8/11/2014

The New York State Department of Financial Services (the “Department”) recently published its proposed rules and regulations (the “Proposed Rules”) for vendors conducting business involving virtual currency. The Proposed...more

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