News & Analysis as of

Risk Assessment Money Transmitter

Hudson Cook, LLP

"OVER THE LINE!"  Where Banking and Gaming Intersect, the CFPB Has Something to Say.

Hudson Cook, LLP on

The line between virtual and reality is getting thinner. Gamers pay gaming companies real currency for virtual in-game currency to buy skins, create the world they want to live in (virtually), or purchase loot that aid in...more

Wilson Sonsini Goodrich & Rosati

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

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

Ballard Spahr LLP

New FinCEN Cryptocurrency Guidance Provides Comprehensive Overview of BSA Application to Crypto Businesses

Ballard Spahr LLP on

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

Bryan Cave Leighton Paisner

FinCEN’s Recent MSB Guidance Also Has Important Implications for Banks

On March 11, 2016, FinCEN issued Guidance reminding MSBs and their agents of their respective AML obligations and, most importantly, reminding MSBs that they are responsible for their agents’ activities. The Guidance reminds...more

Davis Wright Tremaine LLP

Operation Chokepoint and the Brave New World of Criminal Liability - November 2014

The U.S. Department of Justice and banking regulators have stepped up the pace of criminal, civil and administrative actions against banks, payment processors, money transmitters, and other financial institutions, for...more

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