


Analysis: Proposed FATF Guidance for Virtual Assets and VASPs

$220M in Bitcoin May Be Encrypted Forever on IronKey
Stefan Thomas is two failed password attempts away from losing the private keys to $220 million worth of bitcoin forever. This is because Thomas holds the private keys to his bitcoin wallet in an IronKey. “The World’s Most Secure Flash Drive” would rather die than give up its secrets, thanks to a series of built-in…
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What Exactly is a Virtual Asset Service Provider (VASP)?
Cryptocurrency, digital asset, convertible virtual currency… there seems to be an endless list of terms for the same concept. If that wasn’t enough, a cryptocurrency exchange can also be referred to as a Virtual Asset Service Provider(VASP), Virtual Asset Entity, Digital Asset Customer (DACs), Money Service Business (MSB), or any other series of classifications depending…
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FinCEN Proposed Rule Change for Unhosted CVC Wallets

CipherTrace Feedback on Docket No. FINCEN-2020-0002 ; RIN 1506-AB41
November 25, 2020 Via Email to: [email protected] Re: FinCEN Docket Number FINCEN–2020– 0002; RIN number 1506–AB41 CipherTrace welcomes the opportunity to comment on the Financial Crimes Enforcement Network (“FinCEN”)’s proposed rule change regarding the “Threshold for the Requirement To Collect, Retain, and Transmit Information on Funds Transfers and Transmittals of Funds That Begin or End…
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FinCEN’s Proposed Rule Change for Travel Rule Threshold Would More Than Double Compliance Events at US VASPs
This blog is an excerpt from the upcoming CipherTrace 2020 Cryptocurrency Crime and Anti-Money Laundering Report In October 2020 FinCEN released a proposed rule change, lowering the threshold for travel rule information sharing and retention from $3,000 to $250 for all cross-border payments involving US financial institutions The proposed new rule will definitely apply to…
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FATF Releases Virtual Assets Red Flag Indicators of Money Laundering and Terrorist Financing

Best Practices for Monitoring Virtual Currency-Related Transactions at Your Bank

How Impending Virtual Asset Regulations Impact Banks—Even Those That Don’t Think They Do Crypto
As more mainstream consumer and institutional investors embrace cryptocurrencies, it becomes increasingly difficult, if not impossible, for traditional financial institutions to avoid entanglements with the crypto economy. For example, banks face significant counter-party transaction risks from customers interacting with high-risk crypto exchanges—especially when a bank is unable to identify these transactions as to or from…
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