News & Analysis as of September 3, 2025

Know Your Customers

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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

FinCEN Officially Withdraws Know-Your-Customer Rule for Non-Custodial Crypto Wallets

Troutman Pepper Locke on 9/27/2024

On August 19, the U.S. Treasury Department officially withdrew a contentious proposal from 2020 that aimed to impose know-your-customer requirements on non-custodial cryptocurrency wallets....more

FinCEN’s Proposed Rulemaking for Cryptocurrency – The Balance of National Security vs. Privacy

Rothwell, Figg, Ernst & Manbeck, P.C. on 1/6/2021

Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more

FATF Identifies Red Flags for Virtual Assets and Money Laundering

Ballard Spahr LLP on 9/18/2020

The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...more

All Eyes Are on Regulation of Digital Assets as Federal Agencies and Lawmakers Seek to Bring Clarity: Part 1—The SEC, Utility...

Pillsbury Winthrop Shaw Pittman LLP on 9/12/2019

Federal regulators start to address some of the recent questions about digital assets such as tokens and virtual currencies, though many questions remain. U.S. Regulators and Congress are grappling with how to manage the...more

G20 looks at October deadline for cryptocurrency AML regulation standards

Hogan Lovells on 7/30/2018

What has happened? G20 member countries are looking at an October deadline for reviewing a global anti-money laundering (AML) standard on cryptocurrency....more

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