Regulatory Alerts2019-05-09
Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies
The Financial Crimes Enforcement Network issued this interpretive guidance to clarify how existing Bank Secrecy Act regulations apply to business models involving convertible virtual currencies. The document consolidates prior rulings to define key concepts such as money transmission and value substituting for currency, establishing that regulatory obligations depend on factual activities rather than technological labels. It specifically addresses how various entities, including administrators, exchangers, and users, may qualify as money services businesses subject to compliance requirements.
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