A recent federal district court ruling in a criminal anti-money laundering case suggests that the transmission of virtual currency on behalf of another person requires a state money transmission license — even if the state’s money transmission law does not expressly address the regulation …›
On June 24, 2020, the New York State Department of Financial Services (“NYDFS”) announced a series of initiatives designed to provide further guidance and resources for businesses operating in, and potential new entrants into, the virtual currency industry. The initiatives represent the first major …›
On March 24, 2020, the Commodity Futures Trading Commission (“CFTC”) issued its final interpretive guidance (the “Interpretation”) concerning the meaning of “actual delivery” in the context of retail commodity transactions involving “virtual currencies.” The Interpretation provides that, in the CFTC’s view, actual delivery of …›
The New ABC's: Artificial Intelligence, Blockchain and How Each Complements the Other BSA/AML compliance programs in the United States are often associated with high costs and inefficiencies. At the core of the problem is the lack of standardization across institutions and BSA/AML compliance processes such …›
Artificial intelligence (AI) and blockchain technology are two novel innovations that offer the opportunity for us to move beyond our legacy systems and streamline enterprise management and compliance in ways previously unimaginable. Each technology augments the strengths and tempers the weaknesses of the other. …›
In an article authored for Today’s General Counsel, partner Tracy Bacigalupo discusses how new legislation in Maryland, Senate Bill 136, provides Maryland-formed companies with the statutory framework necessary to migrate their businesses to a blockchain-enabled platform. The legislation reinforces Maryland as a ‘go to’ …›
In the third episode of “Understanding Blockchain,” Morrison & Foerster’s Susan Gault-Brown and Dario de Martino discuss one of blockchain’s foundational technologies – cryptography. This ongoing series is dedicated to providing an overall understanding of blockchain technology and how companies can use it to share, …›
It’s all very well to issue regulatory guidance – but it’s what you do to enforce it that really counts. The UK financial services regulatory agencies have imposed fines exceeding $2 million on a UK bank that did not implement enough oversight on an …›
On July 10, 2019, Blockstack Token LLC (“Blockstack”), a wholly-owned subsidiary of Blockstack PBC, a Delaware public benefit corporation, became the first company to have an offering of digital assets qualified by the U.S. Securities and Exchange Commission (“SEC”) under Regulation A. Blockstack is a …›
Recent Congressional activity reflects increasing concern in the fair lending implications of artificial intelligence (AI) in credit underwriting. Congress and regulatory agencies are likely to press financial services providers to better understand the AI they use and to ensure that its use does not …›