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Virtual Currency BSA/AML Anti-Money Laundering

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... more +
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 -
Troutman Pepper Locke

The GENIUS Act: What Is It and What’s Next?

Troutman Pepper Locke on

On June 17, the U.S. Senate voted 68-30 to pass S.1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the Act). This represents a landmark effort by the U.S. Congress to...more

Ballard Spahr LLP

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

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On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

Orrick, Herrington & Sutcliffe LLP

Crypto platform reaches $100 million settlement to resolve alleged compliance failures

On January 4, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of New York virtual currency, anti-money laundering, transaction monitoring, and cybersecurity...more

BakerHostetler

New York State Department of Financial Services Publishes First Crypto Industry Consent Order

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​​​​​​​On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...more

Jones Day

2021 Anti-Money Laundering and Sanctions Year in Review

Jones Day on

2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more

Torres Trade Law, PLLC

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

Torres Trade Law, PLLC on

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

Ballard Spahr LLP

GAO Publishes Report on Nexus Between Virtual Currencies and Human and Drug Trafficking Financing

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The U.S. Government Accountability Office (“GAO”) recently issued a public version of a more detailed and confidential report previously sent to Congress summarizing the GAO’s review of the use of virtual currencies to...more

Burr & Forman

Tuesday’s Rising Regulatory Chorus On Crypto

Burr & Forman on

This past Tuesday, September 21, the chorus calling for more regulation over crypto reached a sort of crescendo. The SEC - Earlier, in September 14 testimony before the Senate Banking Committee [1], former CFTC and current...more

McDermott Will & Emery

FinCEN Announces Anti-Money Laundering Priorities

McDermott Will & Emery on

The Financial Crimes Enforcement Network (FinCEN) recently issued its government-wide anti-money laundering (AML) and countering the financing of terrorism (CFT) priorities (AML/CFT priorities). FinCEN issued the AML/CFT...more

Ballard Spahr LLP

Congress Tasks GAO to Study the Intersection of Money Laundering and Humanitarian Issues:  Human Trafficking and De-Risking

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Fifth Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) makes major changes to the Bank Secrecy Act (“BSA”) and the U.S....more

Morgan Lewis

FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

Morgan Lewis on

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

Orrick, Herrington & Sutcliffe LLP

AML Enforcement Is a Key Tool to Combat Cryptocurrency Crimes

On October 8, 2020, the U.S. Attorney General’s Cyber-Digital Task Force released its Cryptocurrency Enforcement Framework. The Framework makes clear that, in addition to prosecuting bad actors who use cryptocurrency to...more

Orrick, Herrington & Sutcliffe LLP

The CFTC Begins Policing AML Enforcement

Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town.  The Commodity Futures Trading Commission recently finished its fiscal year with...more

Orrick - On the Chain

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

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FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs

Ballard Spahr LLP on

As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

Ballard Spahr LLP on

In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

Orrick - On the Chain

Cryptocurrency and OFAC: Beware of the Sanctions Risks

Orrick - On the Chain on

A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...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

WilmerHale

Anti-Money Laundering and Sanctions: Trends and Developments Emerging Under the Trump Administration

WilmerHale on

Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more

Robinson+Cole Data Privacy + Security Insider

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

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

King & Spalding

Tying It All Together: FinCEN Consolidates Several Years of Cryptocurrency Guidance

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For the past several years, advocates of crypto assets and other public uses of blockchain technology have sought guidance from U.S. regulators regarding the legal implications of new or novel uses of that technology....more

Orrick - On the Chain

FinCEN Shows a Little Bite to Go with Its Bark

Orrick - On the Chain on

Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) laws with respect to cryptocurrency by bringing an enforcement action against...more

Davis Wright Tremaine LLP

Lessons from Recent BSA/AML Enforcement Actions

On February 14, 2019, DWT FinTech co-chair Andy Lorentz gave a presentation on lessons learned from recent BSA/AML enforcement actions–a continued area of emphasis in a de-regulatory climate–to the Innovative Payment Alliance...more

Perkins Coie

Blockchain Week in Review - December 2018

Perkins Coie on

U.S. Developments - SEC Remarks on International Virtual Currency Enforcement - On December 5, 2018, Steven Peikin, Co-Director of the Division of Enforcement at the U.S. Securities and Exchange Commission (“SEC”), gave a...more

A&O Shearman

Financial Action Task Force Clarifies Virtual Asset Regulation

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The Financial Action Task Force has published the outcomes of its plenary on October 17-19, 2018. The FATF considered key issues such as the operations and streamlining of the FATF, major and other strategic initiatives and...more

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