FinCEN’s Recent Civil Money Penalty to a Money Service Business Has Implications for Digital Currency Companies

FinCEN’s Recent Civil Money Penalty to a Money Service Business Has Implications for Digital Currency Companies

In November 2007, Mr. Saleh Adam established a money service business (MSB) called “Adam Service” in Dearborn, Michigan. One of the purposes of the business was to transfer funds on behalf of its customers. Under a typical customer order scenario, Mr. Adam would collect several transfer deposits from customers, pool the deposited funds, and finally remit one… more