The sale of adult-use cannabis has been legalized in 24 states in the United States. But this does not mean there are no other legal impediments to the cannabis industry in those jurisdictions. For example, cannabis...more
El 6/7/22, las Agencias (Junta de Gobernadores del Sistema de la Reserva Federal, la Corporación Federal de Seguros de Depósitos, la Red de Ejecución de Delitos Financieros, la Administración Nacional de Cooperativas de...more
On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a Statement on Bank Secrecy Act Due Diligence for independent ATM owners and operators. The purpose of the statement is to “provide clarity to banks...more
In a January 10 report titled, “Virtual Currencies: Additional Information Could Improve Federal Agency Efforts to Counter Human and Drug Trafficking,” the Government Accountability Office (GAO) identified virtual currency...more
This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more
This writer received three cold emails in two weeks asking for legal help around operating a Bitcoin ATM (BTM). Each groundbreaker asked: “What are the legal requirements for an operator putting a BTM in, say, a coffee shop?”...more