On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more
3/20/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Geographic Targeting Order ,
Money Services Business ,
Regulatory Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more
On 2 January 2025, Massachusetts went from being one of the least regulated states for money transmission to becoming one of the more highly regulated states. Formerly, only entities engaging in foreign money transmission...more
In late 2023, the Consumer Financial Protection Bureau (CFPB) proposed a rule that would subject nonbank fintech companies to the CFPB’s authority. The CFPB articulated that it intends the rule to “level the playing field”...more
On 3 October 2023, the Court heard argument in Consumer Financial Protection Bureau v. Community Financial Services Association, Ltd., No. 22-448. In the matter, the Consumer Financial Protection Bureau (CFPB) challenges the...more
To date, crypto companies have been able to operate in California without a license, but that will change effective July 2025 under the state’s newly-enacted “Digital Financial Assets Law” (the Law), signed by Governor Newsom...more
This is the final part of our series of alerts on the EU’s new Market in Crypto-assets Regulation (MiCA). In this part, we will discuss the authorisation regime under MiCA for specified crypto-asset services which is largely...more
This is Part 2 of a three-part series which examines the main elements of the new MiCA regime in the EU. As a recap, our discussion is based on the Compromise Text (published on 5 October), with references also made to the...more
On 30 June 2022, the new EU Market in Crypto-assets Regulation (MiCA) was agreed on between the European Commission (Commission), the European Parliament (Parliament), and the Council of the European Union (Council). MiCA is...more
In this episode, Jeremy McLaughlin and Justin Wales discuss the state of the cryptocurrency industry, the allure of NFTs, the potential impact of industry regulation, concerns about money laundering, and more....more
Judith Rinearson and Jeremy McLaughlin sit down with payments lawyers to cover the fintech market place, trends, and developments around the world in the Payments Across the Globe miniseries.
In this episode Judith...more
Judith Rinearson and Jeremy McLaughlin sit down with payments lawyers to cover the fintech market place, trends, and developments around the world in the Payments Across the Globe miniseries. In this episode Jeremy McLaughlin...more
Judith Rinearson and Jeremy McLaughlin sit down with payments lawyers to cover the fintech market place, trends, and developments around the world in the Payments Across the Globe miniseries.
In this episode Jeremy...more
In this episode Jeremy McLaughlin and Jonathan Miner discuss the general effects of the pandemic on the cryptocurrency industry, trends that could lead to great consumer adoption of cryptocurrencies, the possible advancement...more
Judith Rinearson and Jeremy McLaughlin sit down with payments lawyers to cover the fintech market place, trends, and developments around the world in the Payments Across the Globe miniseries.
In this episode Judith Rinearson...more
Judith Rinearson and Jeremy McLaughlin sit down with payments lawyers to cover the fintech market place, trends, and developments around the world in the Payments Across the Globe mini-series.
In this episode Jeremey...more
First there were CryptoKitties. Then came digital art, CryptoPunks and NBA Top Shot. But when Beeple’s digital art piece “Everydays: The First 5000 Days” sold at Christie’s for US$69 million, the NFT mania truly began. And as...more
On 24 September 2020, the European Commission (Commission) launched its Digital Finance Strategy (Strategy). The Strategy includes, among other elements: (i) a proposal for a Regulation on Markets in Crypto-Assets with its...more
On September 25, 2020, California Governor Newsom signed AB-1864 into law, which will significantly change the landscape of consumer financial service regulation in the state. The law renames the Department of Business...more
On September 17, the Conference of State Bank Supervisors (CSBS) announced that at least 40 states will establish a joint examination process for “nationwide payments firms” for the 2021 examination cycle. Known as “MSB...more
Since finalizing the “BitLicense” regulatory regime in June 2015, the New York Department of Financial Services (NYDFS) has granted only 25 licenses. This underscores how the BitLicense regulatory framework has been a barrier...more
It’s no secret that accessing the New York market is difficult, if not impossible, for some digital asset companies, especially those in their early stages. New York’s Department of Financial Services (“DFS”) is hoping to...more
1. Q. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) implements the disbursement of $1,200 payments of COVID-19 stimulus funds to millions of Americans. How will the current payment system address the...more
The Massachusetts Supreme Judicial Court (“SJC”) heard argument on February 13, 2020, on whether compliance with a state-mandated default notice could, nevertheless, void foreclosure sales in Massachusetts. ...more
On December 11, 2019, the New York Department of Financial Services (“NYDFS”) published “Proposed Guidance Regarding Adoption or Listing of Virtual Currencies” (“Proposal”). ...more