The following resources take a deep dive into the issues surrounding crypto-tokens and securities law and recognize that, when properly designed, some tokens may not meet the Howey test...more
On Monday, FinCEN issued two advisory rulings responding to requests for clarification regarding the money transmitter status of two virtual currency companies. While the advisory rulings are technically limited to only the...more
Overview -
On January 30, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued two administrative letter rulings that clarify the application of FinCEN’s regulations to...more
Asset Seizures and Arrests Mark Recent Federal Virtual Currency Enforcement Actions -
Federal authorities have initiated several recent enforcement actions that are indicative of continuing regulatory changes in the...more
To address a perceived gap in regulatory treatment of increasingly popular virtual currencies, including Bitcoin, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) released new guidance on...more