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Money Transmitter Financial Institutions Virtual Currency

Wilson Sonsini Goodrich & Rosati

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

Ballard Spahr LLP

PA Department of Banking and Securities: Virtual Currency is “Money”

Ballard Spahr LLP on

On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more

Allen Matkins

Will California License Virtual Currency Issuers?

Allen Matkins on

The California Department of Business Oversight regulates the money transmission business pursuant to the Money Transmission Act, Cal. Fin. Code § 2000 et seq. The Act currently defines "money transmission" as any of the...more

White & Case LLP

NYDFS Requires LIBOR Transition Plans by Early February

White & Case LLP on

On December 23, 2019, the New York Department of Financial Services (NYDFS) issued an Industry Letter instructing each institution it regulates, including banks and licensed Fintechs, to make submissions describing the...more

Orrick - On the Chain

Wyoming, the “Equality State,” Seeks to Level the Playing Field for Digital Assets Businesses

Orrick - On the Chain on

In its continued effort to establish itself as the go-to jurisdiction for digital asset businesses, Wyoming, through its Department of Audit, Division of Banking, recently published a digital asset custody regime for its...more

Ballard Spahr LLP

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

Ballard Spahr LLP on

Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more

Jones Day

NYDFS Rejects Cryptocurrency Exchange License Applications, Citing Compliance Program Flaws

Jones Day on

The Situation: For the first time, the New York State Department of Financial Services ("NYDFS") publicly announced that it had denied a cryptocurrency exchange's applications for virtual currency and money transmission...more

Dechert LLP

Financial Services Quarterly Report - First Quarter 2019: A U.S. Regulatory Patchwork Quilt: Cryptocurrency and Money Transmitter...

Dechert LLP on

According to its original design, Bitcoin was intended to reduce market participants’ need to rely on “financial institutions serving as trusted third parties to process electronic payments.”1 While Bitcoin and other...more

Ward and Smith, P.A.

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on

Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more

Blank Rome LLP

FinCEN Director’s Speech Underscores the Need for Virtual Currency Businesses to Comply with the Bank Secrecy Act

Blank Rome LLP on

Individuals and businesses that accept and transmit virtual currency must register with the Financial Crimes Enforcement Network (“FinCEN”) as a money service business (“MSB”). Registrants must develop and maintain an...more

Ward and Smith, P.A.

Retaining North Carolina's Booming Virtual Currency Industry

Ward and Smith, P.A. on

North Carolina rightfully regards itself as a leader in innovation and as a hub for technology—it hosts Research Triangle Park and world-renowned universities, and according to the NCTech’s 2018 State of Technology Industry...more

Wilson Sonsini Goodrich & Rosati

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

Perkins Coie

FinCEN Is Watching ICOs for BSA Violations

Perkins Coie on

In a recently published letter to the Senate Finance Committee, FinCEN confirmed that when an ICO token is a “convertible virtual currency,” administrators or exchangers of the token would be “money transmitters” under...more

Sheppard Mullin Richter & Hampton LLP

New Hampshire Exempts Bitcoin from Money Transmitter Regulation

The pro-bitcoin legislation trend continues. This month New Hampshire passed legislation that exempts persons using virtual currency from registering as money transmitters. Specifically, the law amends existing RSA 399-G,...more

Perkins Coie

Blockchain Week in Review – April 2017 #3

Perkins Coie on

Below is a summary of some of the significant legal and regulatory actions that occurred over the past week. This alert is not intended to be a comprehensive list of all such developments, but rather a selection of...more

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