The Importance of Knowing Your Employee…

The Importance of Knowing Your Employee…

In January 2014, we saw the arrest of Charlie Shrem, vice president of the Bitcoin Foundation, co-founder and chief executive officer, of BitInstant, and one of Bitcoin’s more prominent advocates.  As the details of the government’s case against Mr. Shrem become known, we are reminded of the basic principles of a dynamic anti-money laundering (AML) program and… more

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

FinCEN and U.S. Department of Justice Lay Groundwork of Notice on Digital Currency Ecosystem

Over the past several years, Financial Crimes Enforcement Network (FinCEN), the Office of Comptroller of Currency (OCC), and the U.S. Department of Justice (DOJ) have issued numerous civil money penalties and enforcement actions to the traditional banking sector for failing to implement an effective anti-money laundering (AML) program reasonably designed to detect suspicious activity. To read more… more

Integrated Identity Verification and Transaction Monitoring for Digital Currency Companies

For years, financial institutions have struggled to develop and implement integrated identity verification, transaction monitoring, and reporting infrastructure.  Typically, financial institutions and non-bank financial institutions, including money service businesses (MSBs) have implemented disparate AML and anti-fraud systems absent an integrated enterprise risk management framework.  In today’s marketplace, financial institutions and MSBs need to be proactive and address… more

Cost-Effective Bank Secrecy Act Compliance For Digital Currency Companies

CoinComply and IdentityMind have announced a partnership to provide the first integrated Know Your Customer (KYC), transaction monitoring, and case management enterprise solution for digital currency companies to perform automated identity verification and transaction monitoring as part of a Bank Secrecy Act (BSA) program. CoinComply, a consultancy specializing in digital currency companies, developed an integrated AML program… more