Bitcoin has been described as a decentralized, peer-to-peer virtual currency that is used like money – it can be exchanged for traditional currencies such as the U.S. dollar or used to purchase goods or services, usually online. Unlike traditional currencies, Bitcoin operates without central authority or banks and is not backed by any government. Perianne Boring Read Quote
Exchanging bitcoin on behalf of ransomware victims should not be construed as criminal activity by the exchanger, not as a matter of law nor as sound policy. Such an interpretation would set a precedent that would surely cause real harm to the public, to the blockchain ecosystem, and to the financial services industry as a whole. Perianne Boring Read Quote
Applying criminal law to the exchange of bitcoin on behalf of ransomware victims would create a morally shocking result of re-victimizing a victim. All lawfully operating digital currency exchanges would thereafter refuse to exchange bitcoin for ransomware victims for fear of criminal culpability. Perianne Boring Read Quote
The law provides a remedy, charging those who threaten a victim’s data for the purpose of extortion. Extending criminal liability to innocent third-party digital currency exchangers, or any other third-party financial institution, would be an utterly unwarranted and unjust misinterpretation both of law and policy. Perianne Boring Read Quote
The key benefits of a Special Purpose National Bank Charter are uniform regulations, standards, supervision, and authority for emerging financial technology companies to operate nationwide. Perianne Boring Read Quote
Blockchain startups are suffering from a crippling, archaic, and antiquated state regulatory system – and it’s driving innovation abroad. Many blockchain start-ups trigger or may trigger money transmitter laws and regulations. Perianne Boring Read Quote
In March 2013, FinCEN issued guidance for virtual currency businesses – giving the industry some degree of clarity about how to be compliant on the federal level. Perianne Boring Read Quote
