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Banking & Financial Services Update

Financial Crimes Enforcement Network Guidance Regarding Convertible Virtual Currencies, Wallets, ICOs, DApps and More

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On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued guidance relating to how the Bank Secrecy Act (BSA) and its implementing regulations relating to money services businesses (MSBs) apply to certain businesses that transact in convertible virtual currencies (CVCs).1 Concurrently, FinCEN issued an advisory on illicit activity involving CVCs that should be reviewed by entities involved in CVCs for incorporation in their anti-money laundering (AML) programs.2 The guidance is discussed in further detail below.

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