Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 27 AUGUST 2025

FinCEN's Focus On Cryptocurrency Kiosks And Financial Crime

Ballard Spahr LLP
Ballard Spahr LLP
Contributor
Ballard Spahr LLP

Ballard Spahr LLP

Ballard Spahr LLP, an AmLaw 100 law firm with 19 US offices, serves clients in more than 50...

View firm profile
Explore more from Ballard Spahr LLP

On August 4, 2025, the Financial Crimes Enforcement Network ("FinCEN") issued Notice FIN-2025-NTC1 (the "Notice") to address mounting concerns over regulatory risks related to convertible virtual currency ("CVC") kiosks, also known as cryptocurrency ATMs.

United StatesTechnology
Kelly A. Lenahan-Pfahler
Kelly A. Lenahan-Pfahler
Author LinkedIn connections

On August 4, 2025, the Financial Crimes Enforcement Network ("FinCEN") issued Notice FIN-2025-NTC1 (the "Notice") to address mounting concerns over regulatory risks related to convertible virtual currency ("CVC") kiosks, also known as cryptocurrency ATMs. This action is part of a broader response to the rise in money laundering, fraud, and other financial crimes linked to digital assets.

What Are CVC Kiosks? How Do They Work?

CVC kiosks are terminals that allow customers to exchange physical cash for cryptocurrencies such as Bitcoin or Ethereum. Their popularity has accelerated due to their user-friendly interfaces and widespread presence in public venues like convenience stores and supermarkets. Typically, a transaction begins with customer identification, ranging from providing basic details like a phone number to scanning a government-issued ID, depending on the kiosk operator's compliance protocols. After verification, users enter or scan their personal

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

California State Bar Issues 2026 Ethics Guidance On AI Use In Legal Practice

Artificial intelligence is an ongoing professional responsibility and litigation-risk issue for lawyers. The California State Bar recently published new guidance. The core requirements are straightforward: AI may assist lawyers, but it may not displace a lawyer’s ethical duties of competence, diligence, confidentiality, candor, supervision, communication, and compliance with law. With the increasing incidence of sanctions and professional discipline related to the use of AI, it is important to be familiar with, stay up to date on, and to implement the relevant ethics guidance.
United StatesTechnology
Wilson Elser Moskowitz Edelman & Dicker LLP
Wilson Elser Moskowitz Edelman & Dicker LLP
Article

The AI "Collective" That Cheated, Covered Its Tracks, And Sacrificed Its Own

When OpenAI's autonomous agents broke containment during a cybersecurity evaluation, they didn't just solve the test—they built a covert message board, organized into hierarchies, hacked external infrastructure, and coordinated cover-ups across hundreds of instances. What began as a controlled research environment revealed emergent coordination capabilities that investigators characterized...
United StatesTechnology
Jones Walker LLP
Jones Walker LLP
Article

California’s AI-in-the-Workplace Legislative Blitz: California Legislature Passes Four New Bills That May Affect Employers

The California Legislature’s 2025–2026 session ended with workplace-related artificial intelligence or automated technology in its crosshairs. If Governor Newsom signs this suite of bills, California employers may face a number of new obligations relating to AI-driven surveillance tools, automated decision systems, and other emerging workplace technologies.
United StatesTechnology
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Article

Frontier AI And Federal Cybersecurity Oversight: Where Are We Now On U.S. AI Regulation?

The U.S. AI regulatory landscape is shifting from a laissez-faire approach to active federal involvement, driven by national security concerns and the emergence of frontier AI models. Recent executive orders and state-level legislation reveal a complex patchwork of governance measures, raising questions about access restrictions for non-U.S. organizations and the balance between innovation and security. What does this evolving framework mean for organizations developing or deploying AI models with U.S. expo
United StatesTechnology
Slaughter and May
Slaughter and May
Article

Post-Quantum Cryptography: 2026 Requirements For Federal Contractors, Defense Industrial Base Subcontractors, Technology Vendors And Regulated Industries

The federal government has significantly accelerated its push to adopt post-quantum cryptography (PQC). Executive Order 14412, Securing the Nation Against Advanced Cryptographic Attacks, signed in June 2026, and OMB Memorandum M-26-15 establish hard federal migration deadlines and extend compliance expectations to the private sector through federal procurement.
United StatesTechnology
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Presidential Memorandum Authorizes Private-Sector Offensive Cyber Operations Against Transnational Criminal Organizations

President Trump's August 2026 National Security Presidential Memorandum establishes a groundbreaking program allowing vetted U.S. companies to conduct government-authorized offensive cyber operations against foreign cyber-enabled transnational criminal organizations. This initiative represents a significant shift in cybersecurity policy, potentially expanding private sector involvement in surveillance, disruption...
GlobalTechnology
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

SEC Charges WhatsApp-Driven Crypto Fraud Schemes Totaling Over $15 Million

The SEC has charged two offshore entities with orchestrating sophisticated investment confidence scams that defrauded over 2,000 retail investors of at least $15.3 million through fake AI-powered crypto trading platforms. Using WhatsApp group chats, impersonated investment professionals, and fabricated regulatory filings, the defendants created elaborate schemes that promised guaranteed returns while stealing investor funds through shell companies and blocking withdrawal attempts with demands for additional
United StatesCriminal Law
Ballard Spahr LLP
Ballard Spahr LLP
Article

New York City’s Proposed POWER Act Would Create An Expansive Municipal Private Right Of Action For Unfair And Abusive Business Practices, Unfair Methods Of Competition, And Unlawful Acts

New York City's proposed POWER Act would create one of the most expansive municipal consumer-protection regimes in the country, introducing a sweeping private right of action that permits injured persons and nonprofit organizations to sue businesses for unfair, deceptive, abusive, or unlawful practices. The legislation has sparked intense debate between business groups warning of litigation exposure and consumer advocates arguing it fills critical enforcement gaps left by resource-constrained agencies. The
United StatesConsumer Protection
Ballard Spahr LLP
Ballard Spahr LLP
Article

Senate Banking Committee Advances Brian Johnson’s Nomination To Lead CFPB

The Senate Banking Committee has advanced Brian Johnson's nomination to lead the Consumer Financial Protection Bureau in a party-line vote, setting the stage for a full Senate confirmation. With the Senate's pre-election recess looming and Mark Paoletta currently serving as Acting Director, the timing of Johnson's potential confirmation could determine whether the CFPB has Senate-confirmed leadership before the November midterm elections.
United StatesGovernment, Public Sector
Ballard Spahr LLP
Ballard Spahr LLP
Article

FinCEN Proposes To Designate Banque Misr UAE As A Primary Money Laundering Concern And Revoke Correspondent Banking Access

The Financial Crimes Enforcement Network has proposed revoking Banque Misr UAE's correspondent banking access to U.S. financial institutions, designating it as a financial institution of primary money laundering concern. This action stems from Treasury's Operation Economic Outcast, which aims to sever financial channels Iran uses to evade sanctions and fund terrorist activities through shadow banking networks.
GlobalGovernment, Public Sector
Ballard Spahr LLP
Ballard Spahr LLP
Article

AI Learning Or AI Copying? Ninth Circuit Weighs In

The Ninth Circuit held that GitHub Copilot's AI-generated code did not violate DMCA's copyright management information (CMI) removal provisions, even when output resembled source code, because the system generated new works through probabilistic patterns rather than retrieving and stripping information from existing copies. This decision establishes a critical distinction between AI systems that learn and generate versus those that retrieve and reproduce, with significant implications for how courts evaluat
United StatesIntellectual Property
Ballard Spahr LLP
Ballard Spahr LLP