Bank Secrecy Act (BSA)

The Office of the Comptroller of the Currency issued Interpretive Letter 1174 on January 4, 2021, clarifying the authority of national banks and federal savings associations to buy, sell, and issue stablecoins and participate in independent node verification networks in order to conduct payment activities and other bank-permissible functions.
Continue Reading OCC Authorizes Banks to Leverage Cryptocurrency Payment Networks

Wyoming recently awarded its second special-purpose depository institution charter to Avanti Bank. Kraken was the first institution to receive the newly created SPDI charter in September. As Wyoming had likely hoped when it passed a flurry of blockchain legislation, it appears that it is starting to take hold as a digital-asset-friendly banking state.
Continue Reading Wyoming Issues Second Crypto Bank Charter

On Monday, October 19, the Financial Crimes Enforcement Network announced a $60 million civil money penalty against Larry Dean Harmon, the founder, administrator and primary operator of unlicensed convertible virtual currency “mixers” for alleged violations of the Bank Secrecy Act and its implementing regulations.
Continue Reading FinCEN Issues $60M Fine for Convertible Virtual Currency BSA Violations

On February 20, 2020, the federal Office of the Comptroller of the Currency (OCC) announced a Bank Secrecy Act enforcement action against a federal savings bank (Bank). This is one of the first, if not the first, public enforcement actions against a bank related to banking cryptocurrency-related operations. Banks that currently provide banking services to cryptocurrency-related companies, or are considering providing banking services to such companies in the future, should carefully review this enforcement action and consider where the quality of the bank’s AML compliance program is commensurate with these high-risk customers.
Continue Reading OCC Announces Crypto Enforcement Action