FinCEN Releases Guidance for Convertible Virtual Currencies


FinCEN released interpretive guidance, FIN-2019-G001, to remind persons subject to the Bank Secrecy Act, or BSA, how FinCEN regulations relating to money service businesses, or MSBs, apply to certain business models involving money transmission of convertible virtual currencies, or CVCs. The guidance does not establish any new regulatory expectations or requirements, but is intended to help financial institutions comply with existing obligations under the BSA as they relate to current and emerging business models involving CVCs.

Advisory FIN-2019-A003 was issued to assist financial institutions in identifying and reporting suspicious activity concerning how criminals and other bad actors exploit CVCs for money laundering, sanctions evasion, and other illicit financing purposes – particularly those involving darknet marketplaces, peer-to-peer exchangers, foreign-located MSBs, and CVC kiosks.

Question of the Week

Q: Can collection effort continue once a member of the armed services goes on active duty?

A: Yes, unless the credit union receives a court order prohibiting it from collecting. The Servicemembers Civil Relief Act does not require collection efforts to stop once a member goes on active duty. However, the servicemember can petition a court for relief and ask for reduced payments or to suspend enforcement of the obligation.

Legal Briefs

Financial Crimes Enforcement Network (FinCEN)

FinCEN reissues real estate geographic targeting orders for 12 metropolitan areas, which includes Seattle.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of May 17. The last update prior to this was May 10.

Questions? Contact the Compliance Hotline: 1.800.546.4465;

Posted in Compliance News.