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Pending Changes to Anti-Money Laundering Program Requirements for MSBs and Other Financial Institutions

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

FinCEN Proposes Significant Expansion of AML/CFT Obligations to Cover Registered Investment Advisers, Venture Capital Advisers,...

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

FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

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

FinCEN Issues ‘First-of-its-Kind’ Order Against Crypto Asset Exchange Linked to Illicit Russian Activity

On January 18, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) designated Bitzlato Limited (Bitzlato), a crypto asset exchange business incorporated in Hong Kong, as a “primary money...more

Focus on Fintech - Q3 2022

Welcome to Wilson Sonsini’s Focus on Fintech newsletter. This quarterly newsletter provides ongoing analysis and commentary on regulatory developments impacting the fintech industry. The third quarter of 2022 has been a...more

Cryptocurrency Exchange Platform Agrees to Pay over $53 Million for Anti-Money Laundering and Sanctions Violations

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

Final Regulations on Beneficial Ownership Will Require “Tens of Millions” of Legal Entities to File Reports

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

Headed to the Metaverse? Be "The One" to Minimize Money Laundering Risk

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

New Rules Will Require Beneficial Ownership Reporting to Federal Regulators by U.S. and Foreign Corporations, LLCs, and Other...

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

National Cryptocurrency Enforcement Team Turns Up the Crypto Heat

Earlier this month, the U.S. Department of Justice (DOJ) announced the creation of a National Cryptocurrency Enforcement Team (NCET) to "tackle complex investigations and prosecutions of criminal misuses of cryptocurrency,...more

MSB or Not MSB? That Is the Question (for Determining Applicability of Anti-Money Laundering Rules)

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

How Gaming Companies Can Become Inadvertent Money Services Businesses

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

Anti-Money Laundering Obligations for Virtual Currency Companies

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

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