He Said, She Said, They Said

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More and more federal and state agencies are weighing in on virtual currency.  Here’s what they are saying:

Financial Crimes Enforcement Network (FinCEN):

  • FinCEN Statement on Providing Banking Services to Money Services Businesses (Nov. 10, 2014)
  • Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Payment System, FIN-2014 (Oct. 27, 2014)
  • Request for Administrative Ruling on the Application of FinCEN’s Regulations to a Virtual Currency Trading Platform, FIN-2014-R011 (Oct. 27, 2014)
  • Application of Money Services Business regulations to rental of computer systems for mining virtual currency, FIN-2014-R007 (Apr. 29, 2014)
  • Whether a Company that Offers Secured Transaction Services to a Buyer and Seller in a Given Sale of Goods or Services is a Money Transmitter, FIN-2014-R005 (Apr. 29, 2014)
  • Application of FinCEN’s Regulations to Virtual Currency Mining, FIN-2014-R001 (Jan. 30, 2014)
  • Application of FinCEN’s Regulations to Virtual Currency Software Development and Certain Investment Activity, FIN-2014-R002 (Jan. 30, 2014)
  • Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies (Mar. 18, 2013)

Jennifer Shasky Calvery, Director FinCEN:

U.S. Securities and Exchange Commission (SEC):

Internal Revenue Service (IRS):

David S. Cohen, Under Secretary of Terrorism and Financial Intelligence:

U.S. Immigration and Customs Enforcement:

U.S. Department of Homeland Security:

United States Senate, Committee on Homeland Security and Governmental Affairs:

U.S. Government Accountability Office (GAO):

Conference of State Bank Supervisors:

Financial Action Task Force (FATF):

Here’s is what the states are saying:

Alabama Securities Commission

California Department of Business Oversight:

California Assembly:

Connecticut Department of Banking, Securities and Business Investments Division:

Florida Office of Financial Regulation:

Kansas Office of the State Bank Commissioner:

Illinois General Assembly:

  • House Bill 5886 — Bill would amend the Transmitters of Money Act to define “virtual currency” as a medium of exchange that operates like currency in some environments, but does not  have all the attributes of real currency.

Maryland Commissioner of Financial Regulation:

Massachusetts Consumer Affairs and Business Regulation

  • National Study Finds Consumers Aware of Virtual Currency, but Have Concerns (Aug. 27, 2014)

State of Nevada Department of Business & Industry:

  • Nevada Financial Institutions Division issues consumer and investor guidance on virtual currency (Apr. 25, 2014)

New York State Department of Financial Services:

  • Excerpts From Superintendent Lawsky’s Remarks On Virtual Currency and Bitcoin Regulation in New York City (Oct. 14, 2014)
  • Proposed New York Codes, Rules and Regulations, Department of Financial Services, Virtual Currencies (Jul. 2014)
  • In the Matter of Virtual Currency Exchanges, Order Pursuant to New York Banking Law §§ 2-b, 24, 32, 102-a, and 4001-b and Financial Services Law §§ 301(c) and 302(a) (Mar. 11, 2014)

Texas Department of Banking:

  • Supervisory Memorandum ¾ 1037 (Apr. 3, 2014)

Washington State Department of Financial Institutions:

State Wisconsin, Department of Financial Institutions:

  • State agency warns consumers to be cautious with virtual currencies (Apr. 30, 2014)

Others:

Isle of Man, Department of Economic Development:

Here’s is what other countries are saying:

Canada’s Federal Government:

Isle of Man:

Swiss Financial Market Supervisory Authority (FINMA):