News & Analysis as of July 18, 2025

Anti-Money Laundering

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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 -

Ten things every VASP should know about the BVI Virtual Assets Service Providers Act, 2022

Carey Olsen on 4/8/2025

The Virtual Assets Service Providers Act, 2022 (the “VASP Act”) came into force on 1 February 2023. The VASP Act regulates virtual asset service providers (“VASPs”) and requires that VASPs be registered with the BVI Financial...more

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

Sheppard Mullin Richter & Hampton LLP on 11/27/2023

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

Wilson Sonsini Goodrich & Rosati on 11/8/2023

On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more

In the First Use of Its Section 9714 Powers, the U.S. Treasury Designated Bitzlato as a Russian-Linked Primary Money Laundering...

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2023

On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more

FinCEN prohibits engagement with virtual currency exchange connected to Russian finance

Orrick, Herrington & Sutcliffe LLP on 1/20/2023

On January 18, the Financial Crimes Enforcement Network (FinCEN) issued its first order pursuant to section 9714(a) of the Combating Russian Money Laundering Act to identify a Hong Kong-registered global virtual currency...more

Louisiana Adopts Virtual Currency License

Shipkevich PLLC on 1/18/2023

Louisiana has become the first state to follow New York's lead in issuing a crypto-specific license, accepting Louisiana Virtual Currency Business Activity (VCBA) license applications as of January 1, 2023. All entities...more

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

BakerHostetler on 1/17/2023

On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

Breakthrough in Italian Cryptocurrency Regulation: Statutory Registration for Providers and Exchangers

Jones Day on 3/17/2022

The Italian Ministry of Economy and Finance ("MEF") issued a new decree ("Decree") requiring that virtual asset/currency service providers promptly enroll in a soon-to-be established special section of the register held by...more

The Extension of FAFT’s ‘travel Rule’ and Implications for Virtual Asset Service Providers in the UK

McDermott Will & Emery on 2/25/2022

The extension of the Financial Action Task Force (FATF) ‘Travel Rule’ to ‘Virtual Asset Service Providers’ (VAPSs) is emblematic of the continued and growing push to bring crypto businesses into the mainstream of financial...more

Power of the Peirce: SEC Commissioner Spends Some of Her Influence on Trying to Help Crypto Network Developers

Orrick - On the Chain on 2/19/2020

SEC Commissioner Hester Peirce continues to be one of the most vocal persons in leadership positions at federal regulators who are promoting innovation in digital currency and the blockchain....more

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