News & Analysis as of September 3, 2025

Cryptocurrency

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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 Addresses Increased Fraud Involving Convertible Virtual Currency Kiosks

Perkins Coie on 8/11/2025

Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on 12/8/2023

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

“Pig Butchering”: FinCEN Issues Alert on Virtual Currency Scam

Ballard Spahr LLP on 9/14/2023

On September 8, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released an alert regarding a notorious virtual currency scam called “pig butchering,” because, unfortunately, it resembles the “fattening a hog before...more

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

Skadden, Arps, Slate, Meagher & Flom LLP on 11/16/2022

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

Ballard Spahr LLP on 10/21/2022

The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Top PHive Crypto Enforcement Notes: September Edition

Paul Hastings LLP on 9/7/2022

Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

FinCEN Reports Spiraling SARs Relating to Ransomware

Ballard Spahr LLP on 10/22/2021

On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more

FinCEN and CFTC Reach Groundbreaking $100 Million AML Settlement with BitMEX

Ballard Spahr LLP on 8/25/2021

Government Alleges Systemic and Deliberate AML Failures - Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring - The Financial Crimes Enforcement Network (“FinCEN”) and...more

Off‐Shore Crypto Exchange to Pay Up to $100 Million to Resolve Enforcement Action with U.S. Regulators

Orrick, Herrington & Sutcliffe LLP on 8/20/2021

The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on 1/29/2021

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

King & Spalding on 11/5/2020

In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...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

Financial Daily Dose 12.12.2019 | Top Story: Fed Holds Rates Steady And Looks to Stay There

Robins Kaplan LLP on 12/12/2019

As expected, the Fed kept interest rates unchanged on Wednesday while also signaling that “they would wait to see how the economy fared before making another move”....more

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on 12/4/2019

Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

In Case You Needed A Reminder – AML/CFT Regulations Apply to Transactions in Cryptocurrencies

Orrick - On the Chain on 11/6/2019

Earlier this month, the leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission released a joint statement reminding individuals...more

Blockchain Week in Review - October 2019

Perkins Coie on 10/18/2019

U.S. Developments - U.S. Federal Regulatory Developments - CFTC, FinCEN, and SEC Leaders Release a Join Statement on Digital Assets - On October 11, 2019, the heads of the Commodity Futures Trading Commission (“CFTC”),...more

FinCEN Director Emphasizes AML Priorities for Casinos, Sports Wagering, Mobile Gaming, and Card Clubs in Las Vegas Speech

Blank Rome LLP on 8/22/2019

As underscored in a recent speech by the director of the Financial Crimes Enforcement Network (“FinCEN”), compliance officers should ensure that their anti-money laundering (“AML”) programs are current with FinCEN’s...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

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

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

Ballard Spahr LLP on 8/13/2018

Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

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Virtual Currency › Suspicious Activity Reports (SARs) › Cryptocurrency

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