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The Department of the Treasury’s recently issued Illicit Finance Risk Assessment of Decentralized Finance is principally intended to provide insight on how illicit actors are abusing decentralized finance (DeFi) services, as well as anti-money laundering (AML) and countering the financing of terrorism (CFT) vulnerabilities unique to DeFi. However, the report also contains critical insight on how Treasury, and, presumably, the Financial Crimes Enforcement Network (FinCEN) within Treasury, view the applicabi
FinCEN has previously issued two guidance documents regarding what it calls “convertible virtual currency” or “CVC,” as well as a number of administrative rulings. The 2013 guidance did not specifically discuss DeFi. The 2019 guidance briefly addresses decentralized applications (“DApps”) and decentralized exchanges, but dedicates only a couple of pages to the topic.
The Risk Assessment dedicates significantly more text to the topic of when a DeFi project might be subject to FinCEN’s rules, particularly as a money transmitter, a type of money services business (MSB). The Risk Assessment states that it “does not alter any existing legal obligations, issue any new regulatory interpretations, or establish any new supervisory expectations.” However, it does make explicit a number of important points that are at best implied in FinCEN’s 2019 guidance and introduces critica
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