On October 11, 2019, the Commodity Futures Trading Commission (the “CFTC”), the Financial Crimes Enforcement Network (“FinCen”) of the U.S. Treasury and the Securities and Exchange Commission (the “SEC”) issued a joint statement reminding “persons engaged in activities involving digital assets of their anti-money laundering and countering of financing of terrorism (“AML/CFT”) obligations under the Bank Secrecy Act.” The statement applied to digital assets that are securities, commodities and “security- or commodity-based instruments such as futures or swaps” and the regulation of such assets by the CFTC, FinCen and/or the SEC. The statement indicates that the regulators will use broad definitions with respect to the characterization of such assets and that AML/CFT obligations may apply to a broker-dealer, mutual fund, futures commission merchant or introducing broker “without regard to whether the particular transaction at issue involves a ‘security’ or ‘commodity’…” The statement made clear that the three regulators believe that a major issue for digital asset activities is the application of AML/CFT obligations regardless of the form that they take.
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