Understanding the FinCEN Guidance
In a world where the casino chips have gone digital, Kenneth A. Blanco, the director of the Financial Crimes Enforcement Network (FinCEN), made a splash at the 12th Annual Las Vegas Anti-Money Laundering Conference. Under the searing August sun, he stressed the importance of adhering to the guidelines regarding suspicious convertible virtual currency (CVC) activity. Released earlier in May, these guidelines aim to guide casinos towards compliance with their obligations under the Bank Secrecy Act (BSA) without introducing new regulatory hurdles—because who needs more paperwork on their desk?
Bridging the Reporting Gap
Blanco highlighted a significant gap in reporting on CVC by casinos, particularly in two hot areas: online CVC casinos and the much-glamorous brick-and-mortar establishments that have embraced virtual currencies. Due diligence is the name of the game here. How can casinos conduct thorough checks on CVC transactions? Blanco urged the industry to use blockchain analytics and incorporate CVC indicators into their Suspicious Activity Reports (SARs).
Encouragement to File SARs
In his most spirited tone, Blanco exclaimed, “I encourage casinos to closely review both documents on FinCEN’s website!” Yes, that’s right, casinos need to keep a hawk eye on any suspicious CVC activity and promptly file SARs. Ransomware attacks and cyber event schemes are lurking behind every digital corner, making casinos prime targets for such operations. Ignoring this is like playing poker with your cards face up—there’s no fun in that!
Global Perspectives on CVC Regulations
The U.K. isn’t far behind in the cryptocurrency conversation. In June, a crypto advocacy center made waves by recommending that Her Majesty’s Treasury considers FinCEN’s guidelines as a model for crypto regulations. However, not all crypto enthusiasts were included; only those holding independent control over crypto assets fall under the purview of the BSA. Open-source software developers, for instance, get a free pass. Just imagine the relief in their poker faces!
The Treasury’s Stance
As if the crypto-rollercoaster wasn’t already a ride, U.S. Treasury Secretary Steven Mnuchin, echoing President Donald Trump’s sentiments, voiced grave concerns regarding cryptocurrencies potentially funding illicit activities. As the reality hits, it becomes clearer that enforcing FinCEN’s regulations on crypto-dealing organizations is not just a technicality but a necessary measure—think of it as the adult supervision you didn’t know you needed.
