On Oct. 11, 2019, the Financial Crimes Enforcement Network (FinCEN), the U.S. Commodity Futures Trading Commission (CFTC), and the U.S. Securities and Exchange Commission (SEC), published a Joint Statement on Activities Involving Digital Assets. The purpose of the Joint Statement was “to remind persons engaged in activities involving digital assets of their anti-money laundering and countering the financing of terrorism (AML/CFT) obligations under the Bank Secrecy Act (BSA).”

Click here for the full GT Alert.

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Photo of Anthony J. Fernandez Anthony J. Fernandez

Anthony J. Fernandez is a member of the Corporate Practice in Greenberg Traurig’s Miami office. He focuses his practice on corporate matters advising domestic and international clients on legal issues within mergers and acquisitions, joint ventures, private offerings, corporate governance, and financing.

Prior…

Anthony J. Fernandez is a member of the Corporate Practice in Greenberg Traurig’s Miami office. He focuses his practice on corporate matters advising domestic and international clients on legal issues within mergers and acquisitions, joint ventures, private offerings, corporate governance, and financing.

Prior to joining the firm, Anthony spent over six years in business within the financial technology and financial services industry, working at PayPal and Standard & Poor’s. He has deep international business and market development experience, primarily focused in Latin America and the Caribbean. Anthony utilizes his business and financial background to apply a strategic approach to his clients’ needs.

Photo of Carl A. Fornaris Carl A. Fornaris

Carl A. Fornaris is Co-Chair of the firm’s Financial Regulatory and Compliance Practice. With 27 years of legal experience, Carl advises a broad range of financial services firms – banks and their holding companies, money services businesses, investment advisers, securities broker dealers, gaming

Carl A. Fornaris is Co-Chair of the firm’s Financial Regulatory and Compliance Practice. With 27 years of legal experience, Carl advises a broad range of financial services firms – banks and their holding companies, money services businesses, investment advisers, securities broker dealers, gaming firms, Fintechs, cryptocurrency firms and other institutions – on all aspects of their business. These include formation and licensing, capital-raising transactions, acquisitions and divestitures, USA PATRIOT Act/BSA/AML compliance and OFAC sanctions programs, cryptocurrency regulation, mobile money and FinTech, federal and state agency enforcement proceedings, Dodd-Frank Act compliance and COVID-19/CARES Act economic stimulus program advice (ranging from Small Business Administration PPP loans to Federal Reserve Main Street program loans). Throughout his career, Carl has counseled clients in their dealings with the Federal Reserve, OCC, FDIC, FinCEN, SEC, FINRA, Florida Office of Financial Regulation, New York Department of Financial Services and other state supervisory authorities.

Carl is also active representing lenders and credit parties in financing transactions, particularly credits to non-U.S. loan parties, asset-based credits, acquisition financing and stand-by letters of credit.

Carl is a past General Counsel of the Florida International Bankers Association and sits on its Board of Directors. Previously, he served as Head of Legal and Compliance for the Latin America region of Barclays Bank PLC, with responsibility for managing legal and compliance matters throughout the region. Carl is an adjunct professor in the Business Law Department of the University of Miami Business School.