McGlinchey Stafford, PLLC
MONTH-IN-BRIEF (Oct 2022)
Banking Law
FinCEN and OFAC Issue First Joint Action in Cryptocurrency Market
By Rachael L. Aspery & Aaron Kouhoupt, McGlinchey Stafford, PLLC
On October 11, 2022, the Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) acted in parallel to issue the first joint action in the cryptocurrency market against Bittrex. Bittrex was a convertible virtual currency (“CVC”) platform with offices primarily in Washington State and was licensed as a money services business (“MSB”) with FinCEN. As a licensed MSB, Bittrex was required to develop, implement, and maintain an effective anti-money laundering (AML) program that was reasonably designed to prevent money laundering and the potential financing of terrorist activities.