On May 9, 2019, the U.S. Financial Crimes Enforcement Network (FinCEN) issued guidance on the application of Bank Secrecy Act (BSA) regulations, specifically those regulations applicable to money services businesses (MSBs), to certain business models involving the transmission of convertible virtual currencies (CVCs) (the “Guidance”).  The Guidance follows previous interpretive guidance issued by FinCEN in 2013 relating to transactions involving the acceptance of currency or funds and the transmission of CVC. Also on May 9,…