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FinCEN issues guidance on application of money services business regulations to virtual currency miners and investors

USA - February 10 2014 On January 30, 2014, the Financial Crimes Enforcement Network ("FinCEN") published two administrative rulings regarding whether companies engaged in...

David E.Teitelbaum, Joel D. Feinberg, Gretchen E. Lamberg.


FTC releases staff report on mobile payments

USA - March 14 2013 On March 8, 2013, the Federal Trade Commission ("FTC") issued a staff report, entitled Paper, Plastic or Mobile: an FTC Workshop on Mobile...

David E.Teitelbaum, James A. Huizinga, John K. Van De Weert, Joel D. Feinberg.


Eleventh Circuit provides helpful guidance on the application of UCC Article 4A’s risk allocation for agreed security procedures

USA - December 5 2012 On November 27, 2012, a divided panel of the Eleventh Circuit held that a bank’s electronic funds transfer agreement failed to shift the risk of unauthorized transfers to its customer under Article 4A of the Uniform Commercial Code (“Article 4A”)....

David E.Teitelbaum.


California Supreme Court holds state disclosure law preempted by National Bank Act

USA - June 22 2012 In a case with potentially significant implications for state regulation of national banks, the California Supreme Court ruled unanimously on June 21, 2012 that a state law mandating the form and content of disclosures printed on the front of convenience checks issued to credit card customers was preempted by the National Bank Act (NBA)....

James A. Huizinga, John K. Van De Weert.