A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors. By Parag Patel, Eric S. Volkman, Douglas K. Yatter, and Deric Behar On October 19, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM) that would … Continue Reading
The bipartisan bill would provide a federal safe harbor for non-custodial blockchain service providers from state money transmission and digital asset licensing laws. By Arthur S. Long, Parag Patel, Yvette D. Valdez, Stephen P. Wink, Pia Naib, and Deric Behar On March 23, 2023, US House of Representatives Majority Whip Tom Emmer (R) and Representative Darren Soto … Continue Reading
A new proposal would subject financial institutions and exchanges to onerous recordkeeping and reporting requirements for certain digital currency transactions. By Miles P. Jennings, Benjamin A. Naftalis, Eric S. Volkman, Margaret Allison Upshaw, and Deric Behar In a surprise release in the waning days of the Trump administration, the Financial Crimes Enforcement Network (FinCEN) division … Continue Reading
FinCEN’s guidance clarifies the applicability of the BSA to a variety of virtual currency businesses. By Todd Beauchamp, Charles Weinstein, Loyal T. Horsley, Cameron R. Kates, and Shaun Musuka On May 9, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued interpretive guidance expanding on previously issued guidance and rulings regarding the … Continue Reading
The enforcement action serves as a reminder that virtual currency exchangers, regardless of size, must comply with the BSA. By Todd Beauchamp and Charles Weinstein The US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) does not care if you are a multinational corporation or an individual operating out of your garage; regardless of size, … Continue Reading
