Bitcoin businesses tend to attract crypto enthusiasts as employees. But does allowing your employees also to be your customers cross an ethical (or legal) line? Let's say you work for a prominent cryptocurrency exchange. The exchange is considering listing a brand new coin. We'll call it Bobcoin....
An AML employee training program is critical to the success of BSA/AML compliance for cryptocurrency businesses, but only truly effective if it includes these key elements. Training your new employees on policies and procedures seems like a no-brainer; it's a check-the-box activity. But thinking of it that...
Robust risk analysis of the coins offered by money services businesses, including bitcoin ATMs, is an industry best practice that will eventually become a formal AML compliance requirement. When you started your business, you probably didn't think too much about the "risk profile" of the tokens...
You might be good at getting your compliance in tip-top shape ahead of an annual review, but could your business pass a surprise examination today? Cryptocurrency businesses that emphasize a culture of compliance are businesses that are built for the long haul. But what does it...
We've explained how the Funds Travel Rule applies to cryptocurrency businesses, but what's the best way to record compliance with the guidance? To this day, no topic in bitcoin compliance causes more confusion than the Funds Travel Rule. Though there has been significant commentary about how the Travel...
A wide range of customer behaviors could read suspiciously. How do you know for sure? Though this is not a complete list, we explain 5 common typologies. Watching for suspicious activity is a key part of keeping your cryptocurrency business in compliance. Of course, your primary...
AML compliance is complex, and it can be difficult for cryptocurrency businesses and startups to dot every last I. Here are some of the most commonly-overlooked bitcoin compliance essentials we run into. Putting together an AML compliance program should be at very the top of the...
When you decide to start a cryptocurrency business, there are very specific AML compliance tasks that you need to take care of before you open your doors. You’ll need to perform a risk assessment and implement an AML compliance program that satisfies the pillars of the Bank...
You're not done once you get your MTL license in-hand. In fact, the hard part has just begun. More and more states are requiring cryptocurrency businesses to obtain money transmitter licenses, and this is a trend that's only going in one direction — toward more states...
Can cryptocurrency businesses be subjected to IRS Title 31 exams? In short, yes. The IRS uses Title 31 to prevent money laundering, meaning more and more cryptocurrency businesses could face the examination. When you were in school, you probably hated tests — especially those pop quizzes...
