On May 12, 2022, Gov. Ron DeSantis signed bill CS/HB 273 (the Bill), amending Florida’s money services business (MSB) laws (i.e., Chapter 560 of the Florida Statutes) to, among other
Continue Reading Florida Gov. Signs Bill that Defines ‘Virtual Currency’ and Eases Licensing Restrictions on Certain Virtual Currency Transactions in the State
convertible virtual currency
FinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset Transactions
On Dec. 18, 2020, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) that would impose on banks and money services …
Continue Reading FinCEN Proposes to Extend Recordkeeping, Reporting, and Identity Verification Requirements to Certain Virtual Currency and Digital Asset Transactions
SEC Issues No-Action Letter Facilitating the Secondary Trading of Digital Assets
On Sept. 25, 2020, the SEC issued a No-Action Letter to FINRA, in response to a previously issued Joint Statement by the SEC and FINRA. This No-Action Letter detailed how…
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The OCC and SEC’s FinHub Issue Guidance on Fiat-Backed Stablecoin Reserves
On Sept. 21, 2020, the Office of the Comptroller of the Currency (the OCC) issued guidance pertaining to whether national banks could hold stablecoin reserves. That same day, the Securities…
Continue Reading The OCC and SEC’s FinHub Issue Guidance on Fiat-Backed Stablecoin Reserves
New York State Department of Financial Services Proposes Framework for a Conditional BitLicense
In 2015, the New York Department of Financial Services (NYDFS) finalized rules creating the BitLicense for virtual currency exchanges operating in New York state. New York is currently the only…
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New York State Department of Financial Services Proposes Guidance on Adoption or Listing of Virtual Currencies by Exchanges
In the summer of 2015, the New York State Department of Financial Services (DFS) finalized its regulatory framework for virtual currency firms seeking to conduct certain virtual currency (VC) business…
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SEC Issues ‘No-Action’ Letters Allowing Sales of Utility Tokens
In a significant step forward for the cryptocurrency industry, the U.S. Securities and Exchange Commission issued its first “no-action” letter (NAL) to a U.S.-based company using utility tokens created for…
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FinCEN Issues Guidance on Application of Regulations to Certain Business Models Involving Convertible Virtual Currencies
On May 9, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) issued “interpretive guidance” addressing how FinCEN’s money services business (MSB) regulations apply to…
Continue Reading FinCEN Issues Guidance on Application of Regulations to Certain Business Models Involving Convertible Virtual Currencies