Regulatory Alerts2013-03-18
Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies
The Financial Crimes Enforcement Network issued interpretive guidance to clarify how Bank Secrecy Act regulations apply to participants in virtual currency transactions. The document establishes that while individual users of virtual currency are not money services businesses, administrators and exchangers are classified as money transmitters subject to registration and reporting requirements. These obligations apply to centralized and decentralized virtual currency activities, whereas such entities are explicitly excluded from being classified as prepaid access providers or foreign exchange dealers.
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