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 Virtual currency businesses get caught in the anti-money laundering (AML) web both coming and going. Financial services businesses such as banks view them as suspect customers and suspect business partners, and either flee or impose stringent information requirements and onerous ongoing monitoring. Meanwhile, the banks may be filing secret reports with the U.S. federal […]
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 […]
