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Published today on KYC360 (riskscreen.com)

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 […]

FinCEN gives us more time again to respond to the crypto NPRM…

FinCEN Extends Reopened Comment Period for Proposed Rulemaking on Certain Convertible Virtual Currency and Digital Asset Transactions Contact Office of Strategic Communications,703-905-3770 Immediate Release January 26, 2021 WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) announced today that it has submitted for publication in the Federal Register an Extension Notice, which will lengthen […]

FinCEN recognizes that 15 days was just not enough for the recent Crypto NPRM’s comment period

FinCEN Extends Comment Period for Rule Aimed at Closing Anti-Money Laundering Regulatory Gaps for Certain Convertible Virtual Currency and Digital Asset Transactions Contact Office of Strategic Communications, 703-905-3770 Immediate Release January 14, 2021 WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) announced today it is reopening the comment period for its recent proposed […]