FinCEN, Tokens and Money Transmission: A Redux

We wrote recently about money transmitters and the state of regulation for token-driven businesses. On May 9th, 2019, the Financial Crimes Enforcement Network (FinCEN) put a number of these questions to rest in its guidance entitled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies” (The Guidance). Money Transmission: Accepting and Transferring Currency or…