What are the money-laundering risks with non-fungible tokens (“NFT’s”) and Decentralized Finance (“DeFI”)?
Non-fungible tokens (“NFT’s) were born with the advent of Crypto-Kitties in 2017, operating on Ethereum. The point about NFT’s is that they are both scarce and more importantly can be unique, unlike a fungible commodity such as Bitcoin. Buyers can…
The Digital Renminbi and the end of American sanctions hegemony
Money can be divided into two categories: token based money, and account based money. Token based money such as currency notes or gold is like a bearer bond: ownership of the thing is the store of value. In the film…
Broker Deal Collateral Requirements: Gamestop, Citadel, Robinhood, Melvin Capital
The strangest thing about the Gamestop issue was the conspiracy theories around payment for order flow, Citadel and Melvin Capital boss Gabe Plotkin. Some assumed that Robinhood had conspired against their users because their biggest customer, Citadel, was bailing out…
Fincen Unhosted Wallets
Fincen, a department of the US treasury responsible for collecting transactional information, put out a notice of proposed rule making in December: “Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital”: DEPARTMENT OF THE TREASURY Financial Crimes Enforcement Network…
January 2021 – Payments, Janet Yellen, Appointment of Michael Barr as Chief Comptroller of OCC
Please see the latest commentary below: PayPod – “Financial crime and the regulatory landscape are two critical things for any payments business or fintech to be aware of. As we begin this new year, this landscape is going to continue…
The impact of Janet Yellen on National Security and AML in 2021
Janet Yellen’s confirmation as treasury secretary is bound to have a significant impact on a range of issues, including but not limited to: Coronavirus and spending: PPP relief, and the potential for increased sympathetic fraud China: Changes in sanctions, particularly…
Frank Slootman: “no strategy is better than its execution”
“The board saw [the former CEO] taking Snowflake to the moon and believed Slootman could pilot the ship to Mars.” Frank Slootman is the CEO of Snowflake, and is one of the most well credentialled CEO’s in Silicon Valley, having…
Anti-Money Laundering Act of 2020
The Anti-Money Laundering Act of 2020 is the biggest change to AML legislation in the US in a generation. Key elements include: Fincen to collect data on UBO’s (whereas EU saw UBO registers). The precise mechanism of implementation has been…
What does the OCC Interpretive Letter mean regarding INVN and Stablecoins means for Payment Companies?
The former Coinbase Chief Legal Officer, who is now Chief Comptroller of the OCC, issued an interpretive letter stating that it was fine for banks to use stablecoins and INVN’s (“blockchains”) Winners: Crypto Exchanges like Coinbase. Banks will have to…
Is OCC Comptroller Brian Brooks is driving the big crypto price boom?
It’s not just hedge funds that are driving the crypto price boom: structural pressure from OCC Comptroller Brian Brooks is also important. As we know from the life of Robert Moses, the post-war New York bureaucrat lionized as the…