Regulators Consider Virtual Currency.

On March 18th, Davis S. Cohen, the Treasury Department's Under Secretary of Terrorism and Financial Intelligence, discussed virtual currencies. Cohen summarized the Financial Crimes Enforcement Network's 2013 guidance concerning virtual currencies, noting that under that guidance, virtual currencies must register with FinCEN as money transmitters. As money transmitters, administrators and exchangers of virtual currency must keep records, and report suspicious transactions. On the other hand, those who use virtual currencies for transactions are not subject to regulatory requirements unless the transaction is over $10,000. Cohen Remarks. Separately, FinCEN Director Jennifer Shasky Calvery discussed the need for financial institutions dealing with virtual currency to have in place effective anti-money laundering and counter terrorist financing ("AML/CFT") controls. Shasky Calvery Remarks. On March 20th, the Washington Post reported that in the wake of the Mt. Gox meltdown, the Securities and Exchange Commission is joining the legions of regulators putting the digital currency under the electron microscope. CoinOp.

Ukraine-related Designations and Sanctions.

On March 20th, the Office of Foreign Asset Control designated sixteen Russian government officials, members of the Russian leadership's inner circle, including a Russian bank pursuant to Executive Order 13661, which was signed by President Obama on March 16th . The sanctions are being made for involvement in the Russian government actions in Ukraine and target government officials, the inner circle that supports them, and Bank Rossiya, the personal bank for officials of the Russian Federation. Treasury News Release.

OFAC Authorizes Student Exchange Program with Iran.

On March 20th, the Office of Foreign Asset Control issued Iran General License G, authorizing accredited U.S. academic institutions to establish and operate undergraduate and graduate academic exchange agreements with Iranian universities. Treasury Action.

OCC Puts a Price on Volcker Rule.

On March 20th, Bloomberg News reported on the OCC's report released on March 19th estimating the implementation costs of the Volcker Rule. Costs of OCC-related implementation could range between $413 million and $4.3 billion, as banks are forced to sell some of their investments at a loss. Most of the banks affected by the new rule have more than $10 billion in assets. Volcker Costs.