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Article

Morrison & Foerster LLP | USA | 12 Jun 2019

Financial Services Report, Summer 2019

NACHA’s Payments Innovation Alliance released its Faster Payments 101 primer for small- to mid-sized financial institutions. The primer is an update

Article

Morrison & Foerster LLP | USA | 3 Jun 2019

Nevada Resident Sentenced for Fraud and Unlicensed Money Transmission in Case Involving Bitcoin

On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months

Article

Morrison & Foerster LLP | USA | 21 May 2019

FinCEN Issues Convertible Virtual Currency Guidance and Advisory

On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a guidance, Application of FinCEN’s Regulations to Certain Business Models

Article

Morrison & Foerster LLP | USA | 17 May 2019

Take Two: Are You a Money Transmitter in Vermont?

Last year, we noted that the Banking Department of the Vermont Department of Financial Regulation had taken the position that its money transmission

Article

Morrison & Foerster LLP | USA | 26 Apr 2019

In a First, FinCEN Assesses Civil Money Penalty Against Peer-to-Peer Virtual Currency Exchanger

On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued a press release announcing a civil money penalty for violations of the

Article

Morrison & Foerster LLP | USA | 13 Mar 2019

Risky Business: FTC Signals Departure From Risk-Based Approach, Proposing NYDFSLike Security Requirements for the Safeguards Rule

With one eye on the New York Department of Financial Services (“NYDFS”) cybersecurity rules and the other on two of its own Commissioners who

Article

Morrison & Foerster LLP | USA | 7 Mar 2019

Financial Services Report - Spring 2019

In the words of Willie Wonka: “Wait a minute strike that, reverse it!” As loyal readers will recall, in our last issue, we tried to stay current in

Article

Morrison & Foerster LLP | USA | 12 Feb 2019

California Invites Comments on Agent of a Payee ExemptionRulemaking to Follow

The California Department of Business Oversight (DBO) has issued an Invitation for Comments (“Invitation”) relating to the scope of the “agent of a

Article

Morrison & Foerster LLP | USA | 9 Jul 2018

Are You a Money Transmitter in California?

As we have noted on multiple occasions (see here, here and here), one of the most important questions in the non-bank payments revolution at least

Article

Morrison & Foerster LLP | USA | 20 Jun 2018

Are You a Money Transmitter in Vermont?

The Banking Department of the Vermont Department of Financial Regulation (the "Banking Department") recently entered into a consent order with a money

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