How do these Guidance items apply to a virtual currency business located in a foreign country? On July 21, 2011, FinCEN published in the Federal Register a final rule on definitions and other regulations relating to money services businesses.[1] An entity may now qualify as a MSB under the Bank Secrecy Act regulations based on […]
Introduction Billions of dollars in fines have been paid by the banking industry for “inadequate” AML programs even though our biggest banks devote huge sums and thousands of people in their efforts to comply. The emerging virtual currency business is just getting its “toes wet” in the serious and high-stakes business of AML compliance. To […]
