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FinCEN Imposes Fine for Failure to Register as Money Services Business Under Bank Secrecy Act

On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) imposed a $35,350 civil money penalty on Eric Powers for failure to register as a Money Services Business under the Bank Secrecy Act.  Mr. Powers was a peer-to-peer exchanger of bitcoin, a digital currency, for nearly two years.  FinCEN has taken the position that such... Read more »

FINRA Establishes Office of Financial Innovation

In a press release dated April 24, 2019, the Financial Industry Regulatory Authority (“FINRA”) announced that it had established the Office of Financial Innovation.  The office is focused on financial technology, otherwise known as FinTech.  Haimera Workie, originally a graduate of MIT and Harvard and now a Senior Director at FINRA,  has been named it... Read more »

SEC Framework for Analysis of Digital Assets; No-Action Relief for Certain Tokens

On April 3, 2019, the Securities and Exchange Commission (the “SEC”) staff released a “Framework for ‘Investment Contract’ Analysis of Digital Assets” setting forth its current approach to determining when a digital asset is a security and when it is not.  The Framework does not add significantly to the SEC’s prior actions and statements in... Read more »

SEC Acts Against Private Fund Asset Transfers

On March 15, 2019, the Securities and Exchange Commission (the “SEC”) took cease and desist action against Talimco, LLC (“Talimco”), a private fund manager, and Grant Rogers, its Chief Operating Officer (“Rogers”), finding that Talimco had sold mortgage participations owned by collateralized debt obligations (“CDOs”) that it managed to a fund (the “Fund”) also managed... Read more »

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