This has been a blockbuster week for cryptocurrency enforcement
actions in the United States against cryptocurrency exchanges. To
cover just two of the major developments that occurred in the past
week, two co-founders of a cryptocurrency exchange, BitMEX, Arthur
Hayes and Benjamin Delo, pled guilty to violating the Bank Secrecy
Act (the BSA) by failing to implement and maintain an anti-money
laundering (AML) program. Shortly thereafter, the court overseeing
the BitMEX prosecution denied a motion to dismiss the indictment
against Samuel Reed, a third co-founder of BitMEX.
This alert breaks down the decision in detail below, but for the
busy reader, here are key takeaways from this decision:
