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Published today on KYC360 (

My new article Checking the Bitcoin Box. It’s about the December 2020 FinCEN Notice of Proposed Rulemaking (NPRM) that would make banks and MSBs keep records of transactions over $3000 and report transactions over $10,000 (aggregations over a 24-hour period, too) involving cryptocurrency and “legal tender digital assets” (LTDA – […]

Please withhold judgment…

… for the new episode of Mr. Watchlist’s DesigNation, entitled “Withholding Judgment”. Just dropping some basic knowledge about Withhold Release Orders (WROs) and Forced Labor Findings, which come out of US Customs and Border Protection (CBP), part of the Department of Homeland Security. Less commentary than I usually do, but […]

OFAC Enforcement Action: BitPay pays $507,375

So, BitPay, which “offers a payment processing solution for merchants to accept digital currency as payment for goods and services”, settled 2,102 apparent violations of multiple programs that were considered non-egregious, but not voluntarily self-disclosed. The total value of the transactions involved was only $128,582.61 (and the actual revenue to […]

Ouch! That hurts!

Mr. Watchlist’s DesigNation is back, after over a month off (there hasn’t been a ton that’s been all that interesting recently, to be honest). But, “A Bit Much?” asks the burning question: why was the BitPay settlement with OFAC (and the BitGo one last year, too, to be honest) so […]

Virtual Currency Reporting coming to Canada

Large Virtual Currency Transaction Report Upload documentation   Reporting entities dealing in virtual currency (VC) have Large Virtual Currency Transaction reporting obligations coming into force on June 1, 2021. Reporting entities can begin developing the Large Virtual Currency Transaction Report (LVCTR) Upload (a means to submit the reports to FINTRAC […]

Finanstilsynet Inspection Report: DLR Kredit A/S

Statement on inspection money laundering inspection in DLR Kredit A / S In December 2020, the Danish Financial Supervisory Authority carried out an inspection of DLR Kredit A / S. The inspection was an investigation of the money laundering area. The inspection included the company’s organization, risk assessment, policies, procedures and internal […]

Fresh Danish! Guidance, that is…

New guidance on section 63 of the Payment Act and the Money Laundering Act A new guide will make it easier for banks and payment institutions to navigate both the Payment and Money Laundering Act. The Danish Competition and Consumer Authority and the Danish Financial Supervisory Authority have prepared the guidelines […]

Finanstilsynet Inspection Report: Saxo Bank

Statement on inspection in Saxo Bank A / S (money laundering area) In June 2019, the Danish Financial Supervisory Authority inspected Saxo Bank A / S. The inspection was an investigation of the money laundering area as part of the ongoing supervision of the company. The inspection included the company’s risk assessment, […]