News & Analysis as of July 19, 2025

Virtual Currency › Cryptocurrency › BSA/AML

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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 -

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

Troutman Pepper Locke on 6/25/2025

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

FDIC's Annual Risk Review Includes Crypto Risks for First Time

Cadwalader, Wickersham & Taft LLP on 8/21/2023

The Federal Deposit Insurance Corporation (“FDIC”) published its annual Risk Review this past Monday, providing an overview of banking conditions for 2022 through early 2023. The FDIC started providing Risk Reviews to the...more

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

Orrick, Herrington & Sutcliffe LLP on 1/6/2023

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

New York State Department of Financial Services Imposes $30 Million Fine in First Cryptocurrency Enforcement Action

White & Case LLP on 8/15/2022

On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more

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

BakerHostetler on 8/15/2022

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

NY Department of Financial Services Outlines How Blockchain Analytics Should Be Used for Compliance

Skadden, Arps, Slate, Meagher & Flom LLP on 5/18/2022

On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more

Tuesday’s Rising Regulatory Chorus On Crypto

Burr & Forman on 9/23/2021

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

FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

Morgan Lewis on 1/20/2021

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

AML Enforcement Is a Key Tool to Combat Cryptocurrency Crimes

Orrick, Herrington & Sutcliffe LLP on 11/13/2020

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

DOJ Cryptocurrency Enforcement Framework Highlights Risk for Those Engaged in Virtual Asset and Cryptocurrency Activity

Fenwick & West LLP on 10/21/2020

In case it was not already clear, the U.S. Department of Justice recently confirmed that ensuring the use of cryptocurrency “is safe, and does not imperil our public safety or our national security, is vitally important to...more

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

Orrick - On the Chain on 5/28/2020

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

G20 calls on countries to adopt FATF crypto standards

Hogan Lovells on 2/28/2020

The G20 has urged countries to adopt the Financial Action Task Force (FATF) standards on virtual assets and virtual asset service providers, which were adopted in June last year. ...more

Cryptocurrency and OFAC: Beware of the Sanctions Risks

Orrick - On the Chain on 1/24/2020

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

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

Robinson+Cole Data Privacy + Security Insider on 5/24/2019

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

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

King & Spalding on 5/21/2019

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

Update: Government Enforcement in the Cryptocurrency Space

Ballard Spahr LLP on 5/10/2019

First Post in a Two-Part Series - Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more

The Financial Action Task Force and Virtual Assets

Foodman CPAs & Advisors on 4/29/2019

The FATF (FATF) is an inter-governmental body with 38 members that sets standards and promotes the implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and threats...more

FinCEN Shows a Little Bite to Go with Its Bark

Orrick - On the Chain on 4/25/2019

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

Blockchain Week in Review - December 2018

Perkins Coie on 12/13/2018

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

Comentarios del Director de FinCEN sobre las Deficiencias en el Cumplimiento de la Moneda Virtual

Foodman CPAs & Advisors on 12/6/2018

El 8 de agosto de 2018, el Director de FinCEN, Kenneth A. Blanco, pronunció un discurso en la Conferencia Técnica (Legal) Chicago-Kent Block 2018. Los puntos más destacados de sus comentarios incluyen...more

Virtual Currency Regulation: It’s Here. It’s There. It’s Everywhere.

K2 Integrity on 9/14/2018

The European Union’s Fifth Anti-Money Laundering Directive recently became binding upon EU Member States. This latest directive must be enacted by member states by January 10, 2020. ...more

FinCEN’s Director Comments on Virtual Currency Compliance deficiencies

Foodman CPAs & Advisors on 9/10/2018

On August 8, 2018, FinCEN Director Kenneth A. Blanco, delivered a speech at the 2018 Chicago-Kent Block (Legal) Tech Conference. Highlights from the commentary include...more

Virtual Currencies, ICOs and the SEC

BCLP on 6/1/2018

The original virtual currency, Bitcoin, started in 2009 as a private form of currency to use in lieu of fiat currency (such as the US dollar or the euro) for online transactions. Largely due to its wide price volatility--in...more

Coinbase Cannot Force Noncustomers to Arbitrate Suit Alleging Violations of BSA/AML Duties

Ballard Spahr LLP on 4/26/2018

Earlier this week, the Eleventh Circuit affirmed, in an unpublished opinion, that Coinbase Inc., an online platform used for buying, selling, transferring, and storing digital currency, could not compel arbitration on a...more

AML/BSA Focus by U.S. Senate Committee Testimony – From Beneficial Ownership to Cryptocurrency

Ballard Spahr LLP on 2/8/2018

This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more

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Virtual Currency › Cryptocurrency › BSA/AML

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