On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more
11/1/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Convertible Virtual Currencies (CVCs) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
NPRM ,
Recordkeeping Requirements ,
Virtual Currency
The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more
6/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Enforcement Actions ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Mitigation ,
State Regulators ,
U.S. Treasury
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) published an Industry Letter detailing the Department’s guidance regarding banking organizations that wish to engage in virtual currency-related...more
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more