FinCEN Guidance and Advisory on Virtual Currencies
On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued both guidance and an advisory on virtual currencies. The 30 page guidance, Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies, explains how FinCEN’s money service businesses regulations apply to convertible virtual currencies (CVCs). There are no new regulatory requirements in the guidance, but rather it consolidates all of the administrative rulings and guidance issued since 2011 and then applies it to CVCs. The 12 page advisory, Advisory on Illicit Activity Involving Convertible Virtual Currency, assists financial institutions in identifying and reporting suspicious activity involving CVCs. The advisory highlights 30 red flags (indicators of illicit conduct) for CVCs suspicious activity.
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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