FinCEN Issues guidance to synthesize regulatory framework for virtual currency

Purpose To summarize FinCEN’s new interpretive guidance on how its regulations apply to business models involving convertible virtual currencies (“CVCs”). Design/methodology/approach Highlights the most significant aspects of FinCEN’s CVC guidance, including several of the CVC business models discussed in the guidance. Findings FinCEN’s latest guidance does not create any new legal requirements but clarifies how existing regulations apply to business models involving CVCs. Practical implications Practitioners advising on CVC issues should be familiar with FinCEN’s latest guidance and how FinCEN regulations may impact their clients. Originality/value Highlights the most important takeaways from FinCEN’s guidance based on our firm’s experience in the CVC space. Lawyers representing clients on CVC issues will find this article valuable.