The model law approved in July for the regulation of virtual currency businesses was finalized and formally issued last week by the National Conference of Commissioners on Uniform State Laws for potential adoption by each of state of the United States. The model law – known as the Uniform Regulation of Virtual Currency Business Act – proposes the regulation of all persons engaged in a “virtual currency business activity” absent an exemption. Among other things, such activity includes exchanging, transferring, or storing virtual currency with or on behalf of residents. Potential licensees must complete an application containing a host of specific information required about the licensee itself and each control person, as well as evidence of a minimum net worth, reserves that a state may require, and other documents. Proposed licensees and registrants must prepare and, once granted their status, maintain policies and procedures addressing information and operational security; business continuity; disaster recovery; anti-fraud; anti-money laundering; preventing funding of terrorist activity; and adherence to the VCBA and other relevant state and federal laws. The final rule publication includes a prefatory note that provides background and color on the model law. (Click here for further details in the article “Model State Law Regarding Virtual Currency Businesses Virtually Finalized” in the August 20, 2017 edition of Bridging the Week.)