As the trend toward greater oversight extends worldwide,
financial regulators continue to monitor how and the extent to
which new cryptocurrency-driven business models are subject to
existing regulations.
We saw an increase in financial regulatory actions toward the
end of 2018 and continue in the first quarter of 2019. On April 18,
for instance, the U.S. Financial Crimes Enforcement Network, or
FinCEN, announced a civil money penalty assessment against a
"peer-to-peer virtual currency exchanger" noting that the
exchanger failed to implement appropriate recordkeeping standards
and AML controls. This comes on the heels of the Financial Action
Task Force on Money Laundering releasing a report on virtual assets
for its member states to implement, the Office of Foreign Assets
Control listing two digital wallets in connection to its list of
designated sanctioned parties from Iran, and the Texas Department
of Banking releasing Supervisory Memorandum 1037 noting
