The Financial Crimes Enforcement Network (FinCEN) has issued guidance on cryptocurrencies

The Financial Crimes Enforcement Network (FinCEN) has issued guidance on cryptocurrencies

By Haiaty | Blockchain Enthusiast | 12 May 2019



The Financial Crimes Enforcement Network (FinCEN) has issued guidance on cryptocurrencies in order to provide regulatory certainty for businesses and individuals.

You can find it here:

In the paper there is also information about Dapps and developers involved on Dapps.


Extracted from paper:


Decentralized (distributed) application (DApp) is a term that refers to software programs that operate on a P2P network of computers running a blockchain platform (a type of distributed public ledger that allows the development of secondary blockchains), designed such that they are not controlled by a single person or group of persons (that is, they do not have an identifiable administrator). An owner/operator of a DApp may deploy it to perform a wide variety of functions, including acting as an unincorporated organization, such as a software agency to provide financial services.58 Generally, a DApp user must pay a fee to the DApp (for the ultimate benefit of the owner/operator) in order to run the software. The fee is commonly paid in CVC. The same regulatory interpretation that applies to mechanical agencies such as CVC kiosks applies to DApps that accept and transmit value, regardless of whether they operate for profit. Accordingly, when DApps perform money transmission, the definition of money transmitter will apply to the DApp, the owners/operators of the DApp, or both.


So as i understand, a Dapp owner (company) and a Dapp operator (Dapp developer) are defined "Money transmitter" and therefore the rules defined to "Money transmitters" are applied to them. So they will need to :

  • comply BSA obligations which requires to maintain the anti-money laundering program (“AML program”),
  • register with FinCEN within 180 days of starting to engage in money transmission.
  • comply with the recordkeeping, reporting, and transaction monitoring obligations set forth in Parts 1010 and 1022 of 31 CFR Chapter X.
  • comply with the “Funds Transfer Rule”30 and the “Funds Travel Rule.” Under the Funds Travel Rule, a transmittal of funds of $3,000 or more (or its equivalent in CVC) may trigger certain requirements on a money transmitter acting as either the financial institution for the transmittor or recipient, or as an intermediary financial institution.


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