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FinCEN Issues guidance to synthesize regulatory framework for virtual currency

Mike Nonaka (Covington & Burling LLP, Washington, DC, USA 20001)
Jenny Konko (Covington & Burling LLP, Washington, DC, USA 20001)
Cody Gaffney (Covington & Burling LLP, Washington, DC, USA 20001)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 27 September 2019

Issue publication date: 16 October 2019

Abstract

Purpose

To summarize FinCEN’s new interpretive guidance on how its regulations apply to business models involving convertible virtual currencies (“CVCs”).

Design/methodology/approach

Highlights the most significant aspects of FinCEN’s CVC guidance, including several of the CVC business models discussed in the guidance.

Findings

FinCEN’s latest guidance does not create any new legal requirements but clarifies how existing regulations apply to business models involving CVCs.

Practical implications

Practitioners advising on CVC issues should be familiar with FinCEN’s latest guidance and how FinCEN regulations may impact their clients.

Originality/value

Highlights the most important takeaways from FinCEN’s guidance based on our firm’s experience in the CVC space. Lawyers representing clients on CVC issues will find this article valuable.

Keywords

Citation

Nonaka, M., Konko, J. and Gaffney, C. (2019), "FinCEN Issues guidance to synthesize regulatory framework for virtual currency", Journal of Investment Compliance, Vol. 20 No. 3, pp. 54-56. https://doi.org/10.1108/JOIC-07-2019-0041

Publisher

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Emerald Publishing Limited

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