Your AML compliance program is only as good as a third party says it is. Thus, annual AML audits are required of all financial institutions, including businesses in the cryptocurrency space and crypto MSBs. The four pillars of BSA/AML compliance established by the Bank Secrecy Act...
It's becoming increasingly more common for financial institutions, including businesses in the crypto space, to receive grand jury subpoenas. Thus, it’s very possible that your cryptocurrency business could be the recipient of one in the not so distant future. The important question is, how should...
Every year, federal agencies (primarily the FBI) issue thousands of National Security Letters (NSLs) to gather information they believe will help national security-related investigations and protect against terrorism and “clandestine intelligence activities.” While cryptocurrency businesses don’t receive NSLs often, the number of NSLs issued has been...
Do bitcoin and cryptocurrency businesses need to keep monetary instrument logs? Yes, as a money services business, money transmitter, this log should be part of an AML program consistent with the expectations of the Bank Secrecy Act and other regulations. Is cryptocurrency money? Maybe you immediately answered "yes,"...
Do bitcoin companies need to file Currency Transaction Reports? In a previous post, we talked about the importance of a strong surveillance and monitoring procedure designed to catch suspicious activity and protect cryptocurrency money services businesses (MSBs) and money transmitters from financial crime, like money laundering. As...
As you manage your cryptocurrency business, you will encounter unusual transactions, potentially every day. What do you do? This is a common situation that cryptocurrency financial institutions face every day, and the solution to keep your business in the good graces of regulators is to file...
Whether you're launching an exchange or are starting small with a cryptocurrency ATM or two, your cryptocurrency business needs a BSA Compliance Officer. As we covered earlier in this series, the BSA Compliance Officer is an essential feature of strong cryptocurrency compliance, keeping your business up-to-date...
What is Enhanced Due Diligence in the context of bitcoin and cryptocurrency? Certain customers may trigger enhanced due diligence review based on certain behaviors that regulators consider to pose a higher risk for financial crime like money laundering. Protecting your business from financial criminals, fraudsters, and regulatory...
Financial criminals and con artists are constantly evolving their methods, finding new, innovative ways to steal your information, your identity, and your hard-earned money. As we approach tax season in 2019, let's focus on a unique fraudster scam the IRS and FinCEN warn about every...
Once you've performed a risk assessment and created a BSA/AML Program and related policies, you've laid a foundation of strong compliance for your cryptocurrency money services business (MSB) -- but you're not done yet. Surveillance and monitoring refers to one of the most essential ongoing bitcoin...
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