News & Analysis as of July 19, 2025

Virtual Currency › Today's Popular Updates › 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

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

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

Torres Trade Law, PLLC on 1/26/2022

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

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

Bitcoin Is “Money” For Purposes Of D.C. Money Transmission Law, Says Federal Court

Morrison & Foerster LLP on 8/17/2020

A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license—even if the state’s...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

NYDFS to Virtual Currency Exchange: Don’t Let the Door Hit You on Your Way Out

Orrick - On the Chain on 4/19/2019

The New York Department of Financial Services virtual currency license is back in the spotlight after NYDFS announced that it had rejected the application of Bittrex Inc., a virtual currency exchange, to conduct virtual...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

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

FinCEN Takes First Action Against Foreign-Located MSB—“The Virtual Currency Exchange of Choice for Criminals”—For Willfully...

Ballard Spahr LLP on 7/31/2017

On July 26, FinCEN, in coordination with the U.S. Attorney’s Office for the Northern District of California (“NDCA USAO”), assessed a $110,003,314 civil money penalty against BTC-e a/k/a Canton Business Corporation (“BTC-e”)...more

Expect the Unexpected: The Year Ahead for the Financial Institutions Sector

Hogan Lovells on 1/13/2017

With contributors across the sector and the globe, we've compiled a review of some of the developments that will affect financial institutions in 2017 and beyond. The one thing that 2016 taught us was to expect the...more

Virtual Currency, Real Risks

Troutman Pepper on 1/28/2015

CSBS publishes Draft Model Regulatory Framework to promote consistent state regulation of virtual currency activities and protect consumers in the event of a breach. In March 2014, “Mt. Gox,” one of the largest and best-known...more

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Virtual Currency › Today's Popular Updates › BSA/AML

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