Gibson Dunn discusses Developments in Virtual Currency

The pace of regulation and enforcement actions relating to virtual currencies has continued to pick up during the fall of 2014. We discuss below the following recent developments: (1) updated guidance from the Financial Crimes Enforcement Network on the applicability of rules regarding licensed money transmitters; (2) proposed rules from the Consumer Financial Protection Bureau that could implicate bitcoin debit cards and other prepaid accounts; (3) the role of the Commodity Futures Trading Commission in regulating virtual currencies; (4) the potential consequences of Internal Revenue Service reporting requirements for foreign accounts; (5) the State of New York’s proposed “BitLicense” regulatory … Read more