Regulatory Alerts2014-10-27
Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System
The Financial Crimes Enforcement Network (FinCEN) issued an administrative ruling determining that a company operating a virtual currency payment system is a money services business under the Bank Secrecy Act. FinCEN concluded that the company acts as an exchanger of convertible virtual currency by accepting real currency and transmitting Bitcoin to merchants, thereby failing to qualify for payment processor or integral transaction exemptions. Consequently, the company must register with FinCEN, implement an anti-money laundering program, and comply with all applicable recordkeeping, reporting, and transaction monitoring requirements.
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