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Virtual Currency › Regulatory Requirements › Financial Institutions

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 -
Wilson Sonsini Goodrich & Rosati

Association of State Financial Regulators Issues Guidance on Virtual Currency for Licensed Money Transmitters

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Recognizing the evolving landscape of digital finance, the Conference of State Bank Supervisors (CSBS), an association of state financial regulators, issued advisory guidance on the treatment of virtual currency held on a...more

Troutman Pepper Locke

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

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On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...more

Alston & Bird

NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict

Alston & Bird on

Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more

Troutman Pepper Locke

NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

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On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more

Seyfarth Shaw LLP

Recent Passing of Hong Kong Stablecoins Bill

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On May 21, 2025, Hong Kong’s Legislative Council passed the Stablecoins Bill, establishing a regulatory framework for stablecoins–cryptocurrencies whose value is tied to an external asset or commodity. This marks an important...more

Carlton Fields

FINRA’s Blueprint for the Metaverse

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In October 2024, FINRA released its blueprint for the securities industry’s use of the metaverse — the metaverse report. The metaverse, often framed as “the next evolution of today’s internet,” is a loosely defined term used...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Torres Trade Law, PLLC

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

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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

Pillsbury Winthrop Shaw Pittman LLP

Legislative Reform Will Reinvent the US Anti-Money Laundering Regulatory Landscape

Pillsbury Winthrop Shaw Pittman LLP on

New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more

Ballard Spahr LLP

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

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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

Katten Muchin Rosenman LLP

Bridging The Week - December 2019 #2

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The New York State Department of Financial Services proposed a self-certification regime for the approval of new digital coins by licensed virtual currency firms similar to the process applied by the Commodity Futures Trading...more

Orrick - On the Chain

Wyoming, the “Equality State,” Seeks to Level the Playing Field for Digital Assets Businesses

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In its continued effort to establish itself as the go-to jurisdiction for digital asset businesses, Wyoming, through its Department of Audit, Division of Banking, recently published a digital asset custody regime for its...more

Ward and Smith, P.A.

Retaining North Carolina's Booming Virtual Currency Industry

Ward and Smith, P.A. on

North Carolina rightfully regards itself as a leader in innovation and as a hub for technology—it hosts Research Triangle Park and world-renowned universities, and according to the NCTech’s 2018 State of Technology Industry...more

Perkins Coie

FinCEN Is Watching ICOs for BSA Violations

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In a recently published letter to the Senate Finance Committee, FinCEN confirmed that when an ICO token is a “convertible virtual currency,” administrators or exchangers of the token would be “money transmitters” under...more

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