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Virtual Currency › Reporting Requirements › Recordkeeping Requirements

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

K2 Integrity

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

K2 Integrity on

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

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

Eversheds Sutherland (US) LLP on

On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...more

McDermott Will & Emery

Special Report - A Primer on Charitable Contributions of Virtual Currency

McDermott Will & Emery on

The explosive growth in virtual currency (also referred to as cryptocurrency, digital assets, tokens and digital currency) is evidence of increasing popularity and acceptance of it as a new investment asset class. With the...more

King & Spalding

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

Latham & Watkins LLP

FinCEN Looks to Rein In Cryptocurrency Transactions

Latham & Watkins LLP on

A new proposal would subject financial institutions and exchanges to onerous recordkeeping and reporting requirements for certain digital currency transactions. In a surprise release in the waning days of the Trump...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping, verification, and reporting requirements for transactions involving virtual currency and...

Eversheds Sutherland (US) LLP on

On December 18, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) to establish new requirements for convertible virtual currency (CVC) and legal tender digital asset (LTDA)...more

Sheppard Mullin Richter & Hampton LLP

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

Sheppard Mullin Richter & Hampton LLP on

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

Sheppard Mullin Richter & Hampton LLP

FinCEN Updates Guidance on Crypto

Sheppard Mullin Richter & Hampton LLP on

FinCEN has issued 2 new guidance documents addressing cryptocurrency and other convertible virtual currency (CVC). The guidance does not establish any new regulatory expectations. Rather, it consolidates current FinCEN...more

Blake, Cassels & Graydon LLP

The Good, the Bad and the Ugly: Revised Regulations to PCMLTFA

Blake, Cassels & Graydon LLP on

The wait is over. On June 9, 2018, the Department of Finance (Department) released the long-awaited amendments to the regulations to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (Revised...more

Morrison & Foerster LLP

The CSBS Finalizes Model Framework for Virtual Currencies

Morrison & Foerster LLP on

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

Proskauer - New Media & Technology

FinCEN Releases Two Rulings Classifying a Bitcoin Payment System and Virtual Currency Trading Platform as MSBs

Proskauer - New Media & Technology on

In its opening salvo bringing bitcoin under the watchful eye of the federal government, the Financial Crimes Enforcement Network (FinCEN) issued a Guidance (FIN-2013-G001) in March 2013 clarifying that anti-money laundering...more

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