FinCEN Fines Firm in First Civil Enforcement Action against a Virtual Currency Exchanger

The Financial Crimes Enforcement Network ("FinCEN") fined Ripple Labs Inc. and its wholly owned subsidiary, XRP II, LLC (collectively, "Ripple Labs"), for acting as a money services business and selling its virtual currency without maintaining an adequate AML program.

In addition to paying a civil monetary penalty, Ripple Labs agreed to engage in "remedial steps" to ensure future compliance with AML obligations.

Previously, FinCEN issued guidance that clarified the applicability of regulations implementing the Bank Secrecy Act, as well as the requirement for certain participants in the virtual currency area to register as money service businesses with FinCEN.

See: FinCEN Press Release; Enforcement Action; Statement of Facts and Violations; Remedial Framework Agreement; FinCEN Guidance.