Christopher L. Allen

Arnold & Porter Discusses Regulators’ Clamp-Down on ICOs, Virtual Currencies, and Blockchain Firms

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If there was ever a regulatory grace period for virtual currencies and blockchain technology, it is officially over.  Five federal regulators—The Financial Crimes Enforcement Network of the US Treasury Department (FinCEN), the Securities and Exchange Commission (SEC), the Commodity Futures …

Arnold & Porter explains New York Takes Lead on Anti-Terrorism and Anti-Money Laundering Enforcement by Proposing Criminal Liability for Compliance Officers

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On December 1, 2015, the New York Department of Financial Services (the DFS) released a proposed rule that would require certain New York-regulated financial institutions (Regulated Institutions) to comply with enhanced anti-terrorism and anti-money laundering (AML) requirements and subject chief …

Arnold & Porter explains US Policy Developments in FinTech and Payments Systems: Federal Reserve Establishes Tasks Forces of Faster Payments and Secure Payments

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FinTech businesses focused on payments systems and foreign exchange have witnessed an explosion of demand in recent years. As these payment systems services continue to gain mainstream acceptance, financial regulators in the US are increasingly interested in monitoring and, as …