Business Regulation & Regulated Industries

Editors (11)

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McGlinchey Stafford, PLLC

Lynette Hotchkiss

Executive Editor, Business Regulation & Regulated Industries
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The Arefin Law Office

D. Sharmin Arefin

Contributing Editor, Business Regulation & Regulated Industries
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Villanova University Charles Widger School of Law

Lev E. Breydo

Contributing Editor, Business Regulation & Regulated Industries
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Carlton Fields

Thomas F. Morante

Contributing Editor, Business Regulation & Regulated Industries
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Core States Group

Dredeir Roberts

Contributing Editor, Business Regulation & Regulated Industries
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Davis Polk

Andrew B. Samuel

Contributing Editor, Business Regulation & Regulated Industries
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Troutman Pepper Hamilton Sanders LLP

Barbara T. Sicalides

Contributing Editor, Business Regulation & Regulated Industries
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Liberty University School of Law

Timothy M. Todd

Contributing Editor, Business Regulation & Regulated Industries
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Haynes and Boone, LLP

Susan A. Wetzel

Contributing Editor, Business Regulation & Regulated Industries
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Hudson Cook LLP

Latif Zaman

Contributing Editor, Business Regulation & Regulated Industries
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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.

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