Convertible Virtual Currency Start-ups And Cryptocurrency Platforms

The Feds are not coming, they are here. All indications point to increased federal scrutiny regarding adequacy of Virtual Currency and Cryptocurrency Platforms’ anti-money laundering (AML) compliance programs. Is your organization ready to meet BSA requirements? Contact us to discuss how our robust compliance offering can improve your chance of complying with regulations.

Regulations define currency, also known as real currency, as the coin and paper money of the United States or of any other country that is designated as legal tender and that circulates and is customarily used and accepted as a medium of exchange in the country of issuance.

Convertible virtual currency has an equivalent value in real currency or acts as a substitute for real currency. Administrators and exchangers of convertible virtual currency are considered MSBs (specifically money transmitters) under FinCEN regulations.

Nearly every state has its own definition of money transmission that triggers licensing requirements. Companies transacting in Bitcoin and other cryptocurrencies are generally required to obtain money transmission licenses from states.

The definition of a money transmitter does not differentiate between real currencies and convertible virtual currencies. Accepting and transmitting anything of value that substitutes for currency makes a person a money transmitter under the regulations implementing the BSA.

We understand the scrutiny that virtual currency platforms are facing. We assist with Money Services Business (MSB) registration and Money Transmitter licensing as well as developing an effective AML Compliance Program.

We also provide AML Audit services, money transmitter rule consulting and much more.