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 […]
On March 1, 2017, the New York State Department of Financial Service’s (the “DFS”) final cybersecurity regulations became effective (see 23 NYCRR § 500). These rules were originally published on September 13, 2016. Just before the end of the year, the DFS published another proposed regulation that eased somewhat the requirements of the original proposal […]
In late February, the Superintendent of the New York State Department of Financial Services (the “DFS”) gave a speech at Columbia Law School on the role of state banking departments in the regulation of financial institutions. New York State has been the capital of the banking industry in the United States since before any of […]
