Crypto and ICOs

Overview

These materials are generally focused on two issues, broadly defined, associated with cryptocurrencies (also called "digital currencies" or "virtual currencies") such as Bitcoin, Ethereum and various decentralized applications ("dApps"), including decentralized finance ("Defi") tokens and non-fungible tokens ("NFTs"). The first is the treatment of these products, particularly cryptocurrencies, for purposes of AML regulations and regulations governing money service businesses. The second is the regulation, or potential for regulation, of various token launches or initial coin offerings ("ICOs") as "securities" or as "commodities." A much broader set of AML material is on the AML Focus Page. In addition, there is a separate Focus Page focused on so-called "fiat currency" and foreign exchange transactions. A separate Focus Page provides fuller materials on the definition of "security."

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