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Video instructions and help with filling out and completing Fincen msb independent review form
So last month a letter was sent from FinCEN to ron wyden he's a senator on the Finance Committee and he had asked some questions of fencin about how it could regulate the icos and what was going on in the cryptocurrency market so in response FinCEN sent a letter to Ron Wyden and it discussed the number of different things about how it supervises BSA the Bank Secrecy Act and AML which is anti money laundering areas of the law and one thing that came out that is I think really interesting to a lot of our clients is ports the end of the letter which I have here it says that generally a developer that sells convertible virtual currency in exchange for another type of value is a money transmitter and must comply with AML so that's concerning because there's a lot of people in the industry who have done.i cos they have done initial coin offerings they went out and sold them but they didn't register as an MSB and so we've been getting a lot of questions from people who are now in that circumstance or are thinking about going on and doing initial coin offerings about just what this letter means Music so this letter doesn't really represent a new rule in fact it's it's neither new norms that are rule it's actually just a communication from the Department of the Treasury to a senator so it doesn't have the force of law it doesn't even have the force of a regulation but it doesn't mean that that's the position that FinCEN is taking now and that means a lot because it means if an issue ever comes up either before a fin Center before a court it's likely the position that the government would take as to whether or not somebody who sold tokens in an initial coin offering was a money services business and therefore was required to comply with all the rules that apply to many services businesses Music so FinCEN which is the Financial Crimes enforcement Network their main concern is that criminals are going to make use of the US banking system to take proceeds of criminal activities so you know they sell drugs they get money and they're going to take that money and use the financial system of the United States to hide it both to hide that they committed a crime and to prevent the government from capturing those proceeds and taking them back either if it's a proceed of drug crime maybe just taking it back if it's a something they stole from some third party like you know fraud the government will take it and give it back to that to that victim so FinCEN works with banks to ensure that this doesn't happen so if criminals take the proceeds of their criminal activity and send it through the bank the bank's required to register some money services business and they have hire people.