Assessment of Civil Money Penalty Against Larry Dean Harmon d/b/a Helix

UNITED STATES OF AMERICA
FINANCIAL CRIMES ENFORCEMENT NETWORK
DEPARTMENT OF THE TREASURY
IN THE MATTER OF:
Number 2020-2
Larry Dean Harmon d/b/a Helix
Akron, Ohio
ASSESSMENT OF CIVIL MONEY PENALTY
I. INTRODUCTION
The Financial Crimes Enforcement Network (FinCEN) has determined that grounds exist to assess a civil money penalty against Larry Dean Harmon, as the primary operator of Helix, and as the Chief Executive Officer (CEO) and primary operator of Coin Ninja LLC (Coin Ninja), pursuant to the Bank Secrecy Act (BSA) and regulations issued pursuant to that Act.1 FinCEN has the authority to investigate and impose civil money penalties on money services businesses (MSBs) that willfully violate the BSA and on current and former employees who willfully participate in such violations.2 Rules implementing the BSA state that “[o]verall authority for enforcement and compliance, including coordination and direction of procedures and activities of all other agencies exercising delegated authority under this chapter” has been delegated by the Secretary of the Treasury to FinCEN.3 At all relevant times, both Mr. Harmon, doing business as Helix, and Coin Ninja were “money transmitters” as defined at 31 C.F.R § 1010.100(ff)(5) and a “financial institutions” as defined at 31 C.F.R § 1010.100(t).

1. The BSA is codified at 12 U.S.C. §§ 1829b, 1951-1959 and 31 U.S.C. §§ 5311-5314, 5316-5332.
   Regulations implementing the BSA appear at 31 C.F.R. Chapter X.
2. Treasury Order 180-01 (July 1, 2014); 31 U.S.C. § 5321(a); 31 C.F.R. § 1010.810(a).
3. 31 C.F.R. § 1010.810(a).