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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,…

In June 2015 New York leapt forward and introduced the BitLicense.  The BitLicense regulations prohibit companies from engaging in “virtual currency business activity” in New York, or with New York residents, without a license.  The idea is that the state will act as a gatekeeper for what is seen as high-risk business activity to ensure that companies dealing in virtual currency are structurally sound and have in place adequate protective measures, such as capital requirements…