Overview.  January 2, 2021.   The newly enacted National Defense Authorization Act[1] (NDAA) imposes the most significant reformation of the Bank Secrecy Act (BSA) and related anti-money laundering (AML) laws since the adoption of the USA PATRIOT Act.  The largest changes are in division F, the Anti-Money Laundering Act of 2020 (the “Act”).   The general intent of…

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…