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FinCEN, Tokens and Money Transmission: A Redux

Insight Sam Miller Sam Miller · June 03, 2019

We wrote recently about money transmitters and the state of regulation for token-driven businesses.

On May 9th, 2019, the Financial Crimes Enforcement Network (FinCEN) put a number of these questions to rest in its guidance entitled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies” (The Guidance).

Money Transmission: Accepting and Transferring Currency or Value that Substitutes for Currency. Specifically stated as being confined to principles FinCEN has already enumerated in earlier guidance, The Guidance does serve to clarify a number of questions either expressly or by reference to non-exhaustive example convertible virtual currency (CVC) business models. Read the full article here.


Sam Miller, Rimon Corporate Partner, advises clients in acquisitions and disposals, corporate finance, corporate and partnership structuring and shareholder, operating and buy-sell agreements, general corporate matters, supply, distribution, consignment and inventory management arrangements, and other commercial transactions. He has extensive experience in the metals and transportation industries as well as with technology start-ups, particularly token-driven blockchain businesses, and also advises clients active in the fine art markets. Sam is licensed in California, England and Wales, and South Africa, with specific expertise in all three jurisdictions. He is adept in helping his clients navigate the intricacies of cross-border business and inward investment. Sam has advised clients in a range of countries, including England, Spain, France, Turkey, Lithuania, Latvia, United Arab Emirates, Israel, South Africa, Hong Kong, South Korea, and the United States. Read more.