Anti-Money Laundering Regulation of Digital Assets

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Presented by

Alma Angotti, Gino Soave, Claiborne (Clay) Porter, Jason Somensatto

About this talk

Within recent months, U.S. and international regulators have been moving swiftly to regulate cryptocurrency in various ways. On February 13, 2018, the U.S. Department of Treasury Financial Crimes Enforcement Network (FinCEN), in a letter to Senator Ron Wyden, Ranking Member on the Senate Finance Committee, reiterated its position that cryptocurrency exchanges are required to register as Money Service Businesses (MSB). The requirement to register as an MSB triggers the obligation to develop, document an anti-money laundering (AML) and sanctions compliance program. In a panel discussion, Alma Angotti, Managing Director and Global Investigations & Compliance Practice Co-Leader at Navigant; Gino Soave, a Director in Navigant’s Global Investigations & Compliance Practice; Claiborne (Clay) Porter, Managing Director and Head of Investigations at Navigant; and Jason Somensatto, Of Counsel at Orrick discuss the practical effects of FinCEN’s position and how companies in this industry can ensure that they don’t run afoul of AML and sanctions regulation and enforcement. Topics to be covered include: -- Determining whether your organization should be registered as an MSB -- Developing, implementing and maintaining an effective AML and sanctions compliance program -- How to address AML and sanctions compliance in an ever changing regulatory environment
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