Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions

The Financial Crimes Enforcement Network (“FinCEN”) is issuing these FAQs to assist covered financial institutions in understanding the scope of the Customer Due Diligence Requirements for Financial Institutions,” published on May 11, 2016 (the “CDD Rule”), available at https://www.gpo.gov/fdsys/pkg/FR-2016-05-11/pdf/2016-10567.pdf . These FAQs provide interpretive guidance with respect

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FinCEN Rules Companies Working with Virtual Currency Are Money Services Businesses

The Financial Crimes Enforcement Network (FinCEN) has announced, in two separate rulings, that companies working with virtual currency in their business operations are money service businesses (MSBs). As an MSB, each company must register with FinCEN, and comply with anti-money laundering risk management and risk mitigation requirements.

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