News & Analysis as of November 15, 2024

Recordkeeping Requirements

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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 -

The Shadow Financial System

White & Case LLP on 6/18/2024

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on 11/14/2023

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Sheppard Mullin Richter & Hampton LLP on 5/15/2019

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

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Virtual Currency › Office of Foreign Assets Control (OFAC) › Recordkeeping Requirements

The Shadow Financial System

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

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