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FinCEN Proposes AML and SAR Filing Obligations for RIAs and ERAs

On February 13, 2024, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would apply comprehensive anti-money laundering and countering the financing of terrorism...more

FinCEN’s Mixer 311 Has Immediate Impacts for U.S. Financial Institutions and De-Fi Protocols

On October 19, FinCEN announced its determination that transactions with foreign operating crypto-mixers, a service that obfuscates the source and destination of transactions on a public blockchain, are of “Primary Money...more

Treasury’s DeFi Risk Assessment Draws Lines in the Sand Around “Control”

On April 6, 2023, Treasury issued its risk assessment for decentralized financial (“DeFi”) services as required by Executive Order 14067. While not guidance, the Risk Assessment can provide some insight into Treasury’s views...more

Top PHive Crypto Enforcement Notes: January Edition

Happy New Year! While the holidays hopefully provided a chance to rest and recharge, things have not slowed down in the world of digital asset enforcement. We see a growing dedication of resources by government law...more

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