Debevoise Discusses Guidance on Applying Bank Secrecy Act Framework to Convertible Virtual Currency

The Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance on May 9, 2019 explaining how the agency intends to apply its existing regulatory framework to companies offering common types of convertible virtual currency (“CVC”) products and services (the “CVC Guidance”).1 Although FinCEN largely summarizes and distills existing guidance, participants in these emerging markets have welcomed additional clarity on the agency’s evolving approach.

This update summarizes the CVC Guidance, outlines its application to specific types of CVC activities and discusses its practical import for the market.

MEET THE NEW FRAMEWORK, SAME AS THE OLD FRAMEWORK?

FinCEN explains that participants in … Read more