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Virtual Currency Bank Secrecy Act

Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender... more +
Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency.    less -
DLA Piper

Blockchain and Digital Assets News and Trends - August 2024

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This monthly bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more

BakerHostetler

Weekly Blockchain Blog - August 2024 #4

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Financial Firms Announce Crypto Initiatives, Stablecoin Growth Continues - A major U.S. crypto investment company recently announced the launch of its Avalanche Trust, which “offers investors the opportunity to gain...more

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

Morrison & Foerster LLP

All Your Sale Are Belong to Us - Mitigating IP and Payments Risk in In-Game Economies

The digital age has ushered in innovative forms of entertainment and commerce, including through the development of in-game economies. In recent years, the digital landscape of gaming has expanded beyond mere entertainment,...more

Ballard Spahr LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

U.S. Indicts KuCoin: What It Means for Cryptocurrency Companies Offering Money Transmission Services to U.S. Customers

In a display of the United States' jurisdictional reach, the Justice Department has indicted KuCoin, a prominent global cryptocurrency exchange, along with founders Chun Gan and Ke Tang, for Bank Secrecy Act (BSA) and...more

Freeman Law

Treasury Department Takes Aim at Convertible Virtual Currency Mixing

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The Treasury Department has recently issued a notice of proposed rulemaking under the Bank Secrecy Act regarding the reporting of convertible virtual currency (“CVC”) mixing....more

Ballard Spahr LLP

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

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On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

Ballard Spahr LLP

“Pig Butchering”: FinCEN Issues Alert on Virtual Currency Scam

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On September 8, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released an alert regarding a notorious virtual currency scam called “pig butchering,” because, unfortunately, it resembles the “fattening a hog before...more

Skadden, Arps, Slate, Meagher & Flom LLP

In the First Use of Its Section 9714 Powers, the U.S. Treasury Designated Bitzlato as a Russian-Linked Primary Money Laundering...

On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more

BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

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On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

Ballard Spahr LLP

NYDFS Releases Virtual Currency Guidance for Banking Organizations

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On December 15, 2022, the New York Department of Financial Services (“NYDFS”) published an Industry Letter detailing the Department’s guidance regarding banking organizations that wish to engage in virtual currency-related...more

Troutman Pepper

Senators Introduce Bill to Extend Anti-Money Laundering Rules to Cryptocurrency

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On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced the Digital Asset Anti-Money Laundering Act of 2022 (the Act) that would extend anti-money laundering and countering of the financing...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

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The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Sheppard Mullin Richter & Hampton LLP

Blockchain Game Developers and FinCEN: When are State Money Transmission Laws Applicable?

The rising prevalence of crypto and virtual currencies has invited the scrutiny of several regulatory bodies who continue to grapple with the unique challenges posed by blockchain technology, FinCEN being one prime example....more

Ballard Spahr LLP

OFAC Sanctions Virtual Currency “Mixer” Tornado Cash and Faces Crypto Backlash

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On August 8, the U.S. Department of the Office of Foreign Assets Control (“OFAC”) sanctioned “notorious” virtual currency “mixer” Tornado Cash, which allegedly has been used to launder more than $7 billion worth of virtual...more

White & Case LLP

New York State Department of Financial Services Imposes $30 Million Fine in First Cryptocurrency Enforcement Action

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On August 2, in its first ever cryptocurrency enforcement action, the New York State Department of Financial Services ("NYDFS") announced it had imposed a $30 million fine on Robinhood Crypto, LLC ("RHC") for failures in its...more

Ballard Spahr LLP

Crypto Compliance Matters: NYDFS Fines Robinhood $30M for Alleged AML, Cybersecurity, and Consumer Protection Violations

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Case Involves Familiar But Instructive Regulatory Findings - The New York Department of Financial Services (“NYDFS”) made clear last week that crypto companies can be held accountable for allegedly failing to comply with...more

Mintz

Cryptocurrency - Compliance Matters

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July was a hot month for crypto enforcement, but August is off to a hot start in its own right. On August 2, 2022, the New York State Department of Financial Services (the “Department”) issued a Consent Order with Robinhood’s...more

Foley & Lardner LLP

What GCs Exploring NFT, Web3 Opportunities Need to Know

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Companies across every industry are jumping into non-fungible tokens (NFTs), seeking to seize what they perceive as huge business opportunities. Attorneys working in the space see myriad reasons to be bullish, despite a...more

Oberheiden P.C.

Tokenization Lawyer – 5 Reasons Why You Might Need One

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What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

Freeman Law

FinCEN Provides Reminder About BSA Reporting Requirements

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FinCEN and Bank Secrecy Act Reporting - On March 7, 2022, the Financial Crime Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury alerted financial institutions “to be vigilant against efforts to...more

BakerHostetler

[Podcast] Blockchain University: Relationship Drama: Cryptocurrencies, Blockchain and the Law

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Our fifth episode provides an overview of the key legal issues facing cryptocurrencies and blockchain in the U.S....more

Harris Beach PLLC

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

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With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

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