What are the money-laundering risks with non-fungible tokens (“NFT’s”) and Decentralized Finance (“DeFI”)?
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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. NFT’s allow specific individual things to be sold and traded on the blockchain. They are both scarce and more importantly can be unique, unlike a fungible commodity such as Bitcoin. Buyers can thus purchase individual NFT’s, and then resell…

The Digital Renminbi and the end of American sanctions hegemony
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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 Die Hard, when Hans Gruber broke into the Nakatomi Plaza at Christmas, he was doing…

How much power should a single AML authority have at the European level have, and how would it interact with national supervisors
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How much power should a single AML authority have at the European level have, and how would it interact with national supervisors

AML: KEEPING FINANCE CLEAN In advance of the Politico Panel today with José Manuel Campa, Chairperson of the European Banking Authority and Sven Giegold from the European Parliament regarding “AML, Keeping Finance Clean”, there are a range of questions to be discussed:    How much power should a single AML authority at the European level…

Fincen Unhosted Wallets
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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 31 CFR Parts 1010, 1020, and 1022 RIN 1506-AB47 Requirements for. This rule would require…

January 2021 – Payments, Janet Yellen, Appointment of Michael Barr as Chief Comptroller of OCC
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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 to evolve. That evolution is the focus of this podcast episode. Our guest on the…

The impact of Janet Yellen on National Security and AML in 2021

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 synthetic fraud China: Changes in sanctions, particularly related to China, Russia and North Korea Money laundering, and combatting terrorism and international financial…

What does the OCC Interpretive Letter mean regarding INVN and Stablecoins means for Payment Companies?

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 have a treasury function to exchange fiat to crypto.  Tether and other well known Stablecoins…

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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 Baron von Hausmann of New York, “bureaucrats” are capable of yielding vast power through relatively…