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Skadden Discusses First OFAC and FinCEN Parallel Enforcement Actions on Virtual Currency

By Alessio Evangelista, Eytan J. Fisch, Khalil N. Maalouf, Javier A. Urbina and Michael A. Darling November 23, 2022 by renholding

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million, respectively, with virtual currency exchange Bittrex, Inc. (Bittrex). …

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

By Satish M. Kini and Byungkwon Lim June 5, 2019 by renholding

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”).…

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

By Andrew Joseph Shipe, Lawton M. Camp, Michael D. Trager, Christopher L. Allen and Anthony Raglani April 30, 2018 by renholding

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 …

SEC Commissioner Talks Old Law and New Frontiers at RegTech Summit

By Michael S. Piwowar March 9, 2018 by renholding

Questions of FinTech and RegTech have been paramount in my mind and, I think it is safe to say, the minds of my fellow Commissioners in recent months.[1]

Old Fields and New Corn

On the paneled walls of the

…

K&L Gates Discusses the Virtual-Currency Businesses Act and Coming Cryptocurrency Regulation

By Jeremy M. McLaughlin and Eric A. Love November 17, 2017 by charlesbluesky

The Uniform Law Commission (“ULC”) is an organization focused on developing and preparing “non-partisan, well-conceived, and well-drafted” state legislation in areas of state law where there is a perceived need for uniformity. In practice, once the ULC releases proposed state …

WilmerHale discusses FinCEN’s First Enforcement Action for Virtual Currency Activity

By Franca Harris Gutierrez, Michael E. Gordon, Katrina Carroll, Elijah M. Alper and Jennifer R. Jacoby June 8, 2015 by ilyabeylin

The US government took its strongest step yet in its oversight of other virtual currency [on May 5, 2015], fining prominent “Bitcoin alternative” company Ripple Labs Inc. $700,000 for what the government called a willful violation of the anti-money laundering …

Gibson Dunn discusses Developments in Virtual Currency

By Judith Alison Lee, Arthur S. Long, Jeffrey L. Steiner and Zhou Zhou February 5, 2015 by miaotingwu

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 …

The CLS Blue Sky Blog

Columbia Law School's Blog on Corporations and the Capital Markets

virtual currency