Founded in Paris in 1920, Gide is a leading international law firm with 12 offices spread throughout the world.
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28 May 2019
Publication | Innovation & Fintech
On 9 May 2019, the Financial Crimes Enforcement Network (“FinCEN”), published a guidance that specified the scope of application of FinCEN’s regulations to certain activities involving convertible virtual currencies. FinCEN is a bureau of the U.S. Department of the Treasury in charge of combatting money laundering and terrorist financing.
The timing of this publication is not insignificant. It coincides with the transposition by several European Union Member States of the provisions of the 5th Anti-Money Laundering Directive relating to virtual currencies and comes a few weeks before the plenary meeting of the Financial Action Task Force ("FATF") to be held in Orlando, Florida, in mid-June 2019. On this occasion, FATF members will be invited to approve the interpretative note clarifying recommendation 15, updated in October 2018, which subjects "virtual asset service providers" to the applicable AML/CFT obligations.
Contents of this article:
Click on the PDF below to read the article in full, written by Stéphane Puel, Gide managing partner, and Jennifer D'hoir, member of Gide 255.
