Often Dealing with Cryptocurrency? Your Business Could Be An MSB, with AML, Sanctions Obligations

Money Services Businesses anti-money laundering compliance

Companies regularly engaged with cryptocurrency often meet the criteria to be money services businesses (MSBs) under federal regulation and are required to implement anti-money laundering programs and ensure OFAC sanctions compliance. This article will explore why such businesses are often MSBs under federal law, what kinds of MSBs such businesses are, and the basics of …

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DOJ N. Korea Complaint Illustrates Virtual Currency Laundering Techniques, & US Government, Exchange Responses

North Korea Money Laundering Sanctions

The US Attorney’s Office for the District of Columbia’s recent civil forfeiture complaint against virtual currency allegedly stolen or laundered by North Korean actors illustrates money laundering techniques specific to virtual currencies. Just as significantly, the complaint demonstrates methods governments and financial institutions can use to prevent such schemes, or at least catch the perpetrators once the …

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Targeted Sanctions May Be Best Tool To Combat Rogue Cryptocurrency Exchanges

targeted sanctions rogue exchanges crypto

Not all cryptocurrency transactions need to be viewed as suspect. In fact, a 2019 evaluation by Chainanalysis indicates a significantly lower percentage of economic bitcoin activity was comprised of illicit transactions in 2018 than in 2012. But just because more legitimate economic actors are using cryptocurrency doesn’t mean that bad actors aren’t still exploiting cryptocurrency’s vulnerability. This …

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AML Risks Mean Financial Institutions Need Caution When Working with Cryptocurrency

bitcoin ethereum compliance risk

It is not a secret that cryptocurrency presents anti-money laundering and counter terrorist financing issues for financial institutions. But what is it exactly about cryptocurrency that makes it so risky? A 2018 Allen & Overy article explains the unique issues for financial institutions presented by cryptocurrency from an anti-money laundering perspective. In some respects, the challenges presented …

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2020 Saw EU Member States Take Big Step to Legitimize Use of Cryptocurrency

European Union anti-money laundering regulations

The date for EU Member States to implement into national legislation the Fifth European Union Anti-Money Laundering Directive (AML 5) came and went this past January, and this was a significant development. AML 5, which makes several steps toward strengthening the EU’s anti-money laundering and combatting the financing of terrorism regulatory scheme, is especially important for …

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Effective AML Compliance at Cryptocurrency Exchanges

There is a lot of talk in the emerging cryptoeconomy as to when regulations apply to crypto-oriented services, but when it comes to Anti-Money Laundering (AML), Know Your Customer (KYC), and Combating the Finance of Terrorism (CFT), there is also the question of what an effective cryptocurrency compliance program might look like. Craig Adeyanju at …

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