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The Federalization of Bitcoins
On March 18, the Financial Crimes Enforcement Network of the Treasury Department (FinCEN) issued guidance on the application of its regulations: 'Application of FinCEN's Regulations to Persons Administering, Exchanging, or Using Virtual Currencies.' Much of its attention is focused on the bitcoin, a virtual currency introduced in 2009, although this currency is not mentioned by name.'
FinCEN's jurisdiction is, in part, the regulation of money services businesses. Such businesses, including those deemed money transmitters, are subject to reporting requirements, such as reports on currency transactions, including suspicious activities related to such transactions. See, 31 C.F.R. section 103.20. Criminal and civil penalties apply to the non-registered and non-reporting money services businesses. See, 31 C.F.R. section 103.41(e).
FinCEN relies on the facts and circumstances of the provided services to determine whether the broker or dealer is acting as a money services business. Therefore, the creation and transmission of bitcoins is germane to FinCEN's decision to deem certain bitcoin transactions as performed by money services businesses.
Yachts, Jets, Horses & Hooch: Specialized Commercial Leasing Models
Defining commercial real estate asset class is essentially a property explaining how it identifies — not necessarily what its original intention was or what others think it ought to be. This article discusses, from a general issue-spot and contextual analysis perspective, how lawyers ought to think about specialized leasing formats and the regulatory backdrops that may inform what the documentation needs to contain for compliance purposes.
Hyperlinked Documents: The Latest e-Discovery Challenge
As courts and discovery experts debate whether hyperlinked content should be treated the same as traditional attachments, legal practitioners are grappling with the technical and legal complexities of collecting, analyzing and reviewing these documents in real-world cases.
Identifying Your Practice's Differentiator
How to Convey Your Merits In a Way That Earns Trust, Clients and Distinctions Just as no two individuals have the exact same face, no two lawyers practice in their respective fields or serve clients in the exact same way. Think of this as a "Unique Value Proposition." Internal consideration about what you uniquely bring to your clients, colleagues, firm and industry can provide untold benefits for your law practice.
Risks and Ad Fraud Protection In Digital Advertising
The ever-evolving digital marketing landscape, coupled with the industry-wide adoption of programmatic advertising, poses a significant threat to the effectiveness and integrity of digital advertising campaigns. This article explores various risks to digital advertising from pixel stuffing and ad stacking to domain spoofing and bots. It will also explore what should be done to ensure ad fraud protection and improve effectiveness.
Turning Business Development Plans Into Reality
This article offers practical insights and best practices to navigate the path from roadmap to rainmaking, ensuring your business development efforts are not just sporadic bursts of activity, but an integrated part of your daily success.