Money services businesses (MSBs), a category which includes money transmitters (e.g., PayPal and other payment facilitators), as well as administrators and exchangers of convertible virtual currencies (e.g., Bitcoin...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a sweeping expansion of the Bank Secrecy Act’s (BSA) affirmative anti-money laundering (AML) and countering the financing of...more
2/27/2024
/ AML/CFT ,
Anti-Money Laundering ,
Banking Sector ,
Compliance ,
Financial Adviser ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Terrorist Financing
On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more
M&A transactions involving financial services providers—including tech-based providers or “fintechs”—raise a host of unique questions based on the types of services they provide, which are often highly regulated and may...more
6/16/2023
/ Acquisitions ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
Cybersecurity ,
Data Privacy ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Foreign Investment ,
Mergers ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agencies
Regulators are increasingly taking enforcement action against crypto asset industry participants for violating anti-money laundering (AML) and sanctions laws. Regulators are concerned about the illicit use of crypto...more
6/14/2023
/ Anti-Money Laundering ,
Corporate Counsel ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Currency ,
Financial Instruments ,
Money Laundering ,
Money Services Business ,
NYDFS ,
U.S. Treasury
Earlier this month, the U.S. Department of the Treasury (Treasury) released its Illicit Finance Risk Assessment of Decentralized Finance (Assessment). This Assessment, part of a broad regulatory scrutiny of entities that...more
On October 11, 2022, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced settlements with Bittrex Inc. (Bittrex). The settlements arise from violations of...more
10/19/2022
/ Anti-Money Laundering ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions
On September 30, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published its final regulations on Beneficial Ownership Information (BOI) Reporting Requirements. The regulations...more
Two recent federal enforcement actions—announced the same day—have underlined the need for crypto companies to carefully consider their anti-money laundering (AML) obligations or else risk significant penalties....more
Wilson Sonsini provides extensive and cutting-edge legal services for innovators, technology pioneers, and disruptors. As part of our focus on emerging technologies, our attorneys are publishing a series on applying and...more
The global NFT (non-fungible token) market now is worth dozens of billions of dollars annually. Innovators and early adopters, marketplaces, and sellers, are all eager to join this market but may have questions about how to...more
5/24/2022
/ Anti-Money Laundering ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Economic Sanctions ,
Financial Institutions ,
Financial Markets ,
Money Laundering ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Virtual Currency
On December 8, 2021, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) published its proposed regulations on beneficial ownership information (BOI) reporting requirements. These FinCEN regulations will...more
Over the last 20 years, commerce, finance, and banking have become increasingly digital. Anti-money laundering (AML) regulators have found themselves catching up with the pace of technological innovation.1 As AML regulators...more
Many federal anti-money laundering (AML) laws require proactive steps to guard against financial crime. While these laws requiring proactive measures generally apply only to financial institutions, gaming companies may...more
Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more
4/4/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Compliance ,
Enforcement ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Know Your Customers ,
Money Services Business ,
Money Transmitter ,
Popular ,
Virtual Currency