In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital...more
4/16/2025
/ Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Financial Crimes ,
Investment ,
National Security ,
Regulatory Reform ,
Securities Regulation ,
Trump Administration
On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more
Recent developments in the world of crypto have come at a rapid pace to open 2025 not only signaling but, in some instances, explicitly declaring the Trump Administration’s intent to significantly relax or eliminate...more
3/10/2025
/ Anti-Money Laundering ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
Financial Regulatory Reform ,
FinCEN ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Trump Administration
As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more
11/27/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CFTC ,
Consent Order ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
FinCEN ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Plea Agreements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Suspicious Activity Reports (SARs)
On June 5, 2023, the SEC filed an extensive civil complaint against Binance Holdings Limited, its assorted affiliates and its beneficial owner and CEO, Changpeng Zhao, alleging multiple violations of the Securities Act of...more
Questions of which, if any, regulatory regimes apply to the variety of participants in the cryptocurrency market continue to dog the industry. On February 28, 2022, whether a cryptocurrency futures trading platform...more
On June 21, 2019, the Financial Action Task Force (“FATF”), a multi-national, inter-governmental body established in 1989 “to set standards and promote effective implementation of legal, regulatory and operational measures...more
7/12/2019
/ Administrative Interpretation ,
Anti-Terrorism Financing ,
Cryptocurrency ,
Digital Assets ,
FATF ,
Financial Action Task Force ,
Financial Transactions ,
Money Laundering ,
New Guidance ,
Regulatory Oversight ,
Regulatory Standards ,
Terrorist Financing Regulations ,
Travel Rule ,
Virtual Currency
Some Answers — Producing Even More Questions -
On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) published a comprehensive “interpretive guidance” (the “Guidance”) to “remind” businesses and individuals...more
5/31/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Digital Wallets ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Interpretive Rule ,
Money Services Business ,
Money Transmitter ,
Peer-to-Peer ,
Risk Assessment ,
Token Sales
First Post in a Two-Part Series -
Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more
5/10/2019
/ BitLicense ,
BSA/AML ,
Cryptocurrency ,
Currency Transaction Reports (CTR) ,
Darknet ,
Enforcement Actions ,
Money Laundering ,
Money Services Business ,
NYDFS ,
Peer-to-Peer ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Virtual Currency
As we previously have blogged, the Financial Crimes Enforcement Network (“FinCEN”) became one of the first regulators to wade into the regulation of cryptocurrency when it released interpretive guidance in March 2013 stating...more
3/9/2018
/ AML/CFT ,
Bitcoin ,
Blockchain ,
Broker-Dealer ,
CFTC ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Enforcement Actions ,
Financial Instruments ,
Financial Markets ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Interpretive Rule ,
Money Services Business ,
Money Transmitter ,
Mutual Funds ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Token Sales ,
Virtual Currency