Application of Bank Secrecy Act Regulations to Certain Business Models Involving Convertible Virtual Currencies- Summary

Updated 07/07/2021

This tool summarizes the FinCEN’s guidance addressing requirements under the Bank Secrecy Act (BSA) for financial institutions servicing customers with convertible virtual currency (CVC) transactions. The following are the key takeaways of the changes:

The applicable BSA provisions depend on the specific business model of the individual CVC.
The name of a specific CVC business model does not determine the property rights or the BSA requirements for that specific business model. Rather, property rights of a client in a specific CVC business model determine the manner in which the BSA applies.
The FinCEN guidance does not impose or create any new requirements under the BSA or any other existing provision. The guidance culminates existing requirements and applies these requirements to some of the most commonly existing CVC business models.

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