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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... 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 -
White & Case LLP

The Shadow Financial System

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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

Skadden, Arps, Slate, Meagher & Flom LLP

NY Department of Financial Services Outlines How Blockchain Analytics Should Be Used for Compliance

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On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more

Morrison & Foerster LLP

Analyze This: The NYDFS Sets Clear Crypto Transaction Monitoring Expectations

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The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters....more

Morrison & Foerster LLP

OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

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Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

Foodman CPAs & Advisors

OFAC Warns FFIs And Crypto Sector On Ransomware Attacks

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During the first half of 2021, 68 different ransomware attacks extracted approximately $600 million from victims across the United States. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) says that the...more

Proskauer - Blockchain and the Law

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

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Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

The Volkov Law Group

Cryptocurrency and the Unbanked: How the Blockchain Can Benefit the Impoverished

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I recently came across a paper prepared by students from Columbia’s School of International and Public Affairs that delves into the benefits that cryptocurrency and the blockchain can provide to the world’s unbanked....more

The Volkov Law Group

CFTC Opens Inquiry into Binance, One of the World’s Largest Cryptocurrency Exchanges

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On Friday March 12, Bloomberg News reported that the Commodity Futures Trading Commission (“CFTC”) has opened an inquiry into Binance Holdings Ltd. (“Binance”) to investigate allegations that the exchange allowed US citizens...more

Rothwell, Figg, Ernst & Manbeck, P.C.

FinCEN’s Proposed Rulemaking for Cryptocurrency – The Balance of National Security vs. Privacy

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Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more

The Volkov Law Group

DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)

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DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more

Hogan Lovells

UK FCA becomes AML/CFT crypto supervisor

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The UK Financial Conduct Authority (FCA) has become the anti-money laundering and countering the financing of terrorism (AML/CFT) supervisor for some types of cryptoasset businesses. These will need to meet certain...more

Robinson+Cole Data Privacy + Security Insider

New FinCEN Cryptocurrency Guidance Clarifies Applicability of Anti-Money Laundering Regulations to Virtual Currency Business...

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The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more

Ward and Smith, P.A.

Should You Bank a Virtual Currency Business?

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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

Wilson Sonsini Goodrich & Rosati

Anti-Money Laundering Obligations for Virtual Currency Companies

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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

Ballard Spahr LLP

AML/BSA Focus by U.S. Senate Committee Testimony – From Beneficial Ownership to Cryptocurrency

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This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more

Ballard Spahr LLP

Court Enforces — Partially — IRS “John Doe” Summons Served on Virtual Currency Exchanger

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Last week, a federal magistrate judge in the Northern District of California granted in part and denied in part a motion by the IRS to enforce a “John Doe” summons served on Coinbase, Inc., which operates a virtual currency...more

K&L Gates LLP

Blockchain Energizer Vol. 11

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There is a lot of buzz around blockchain technology and its potential to revolutionize a wide range of industries from finance and healthcare to real estate and supply chain management. Reports estimate that over $1.4 billion...more

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