News & Analysis as of September 2, 2025

Financial Crimes

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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

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

Daily Financial Regulation Update -- Monday, April 24, 2023

Paul Hastings LLP on 4/24/2023

April 21, 2023- Assistant Secretary of the Treasury for Terrorist Financing and Financial Crimes Elizabeth Rosenberg and Deputy Homeland Security Adviser Joshua Geltzer hosted a roundtable at the U.S. Department of the...more

2021 Anti-Money Laundering and Sanctions Year in Review

Jones Day on 3/10/2022

2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more

Cryptocurrency: Wild West or Wall Street? [More with McGlinchey, Ep. 22]

McGlinchey Stafford on 5/27/2021

Every day, the mainstream media and social media are filled with references to cryptocurrency. Depending on who you ask, it’s either simply the next way to spend your money, or it’s a haven for criminal activity. In this...more

Proposed Rules for Transactions with Unhosted Virtual Currency Wallets

K2 Integrity on 1/6/2021

On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury announced highly anticipated and controversial new proposed requirements designed to mitigate illicit finance risks...more

DOJ Demonstrates its Ability to Track Illegal Foreign Funds Laundered Through Crypto; Financial Institutions Must Keep Up

Orrick, Herrington & Sutcliffe LLP on 9/2/2020

The Department of Justice (DOJ) announced last week and earlier this month civil forfeiture actions brought by the United States Attorney’s Office for the District of Columbia to seize stolen or laundered virtual currency...more

The implementation of the Fifth Anti Money Laundering Directive in German Law – Tighten the tight?

Orrick, Herrington & Sutcliffe LLP on 12/6/2019

In the course of the “Panama Paper” scandal, Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing – known as 4. Anti-Money Laundering...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

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