Morrison Foerster is an international law firm with lawyers practicing throughout the United States, Asia, and Europe. Click to discover more.

mofo_share_image.jpg

Morrison Foerster

favicon.ico

favicon-16x16.png

favicon-32x32.png

apple-touch-icon.png

MoFo Favicons

Terms / Notices

Cookies

Privacy Policy

Attorney Advertising

Secure Login

Alumni

  Facebook

MoFo Facebook

  Linkedin

MoFo LinkedIN

Twitter

MoFo Twitter

YouTube

MoFo Youtube

Morrison Foerster - Footer

You have not solved the recaptcha challenge yet or session expired, try again.

Disclaimer

Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our <a href="https://www.mofo.com/about/privacy-policy.html">Privacy Policy</a>, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.

Feedback

mofo-logo-2022.svg

People

Capabilities

Resources

About

Culture

Offices

Careers

Stay Connected

Marc-Alain Galeazzi spoke to Law360 about the Financial Crimes Enforcement Network's (FinCEN) proposal to implement a no-action letter process.



FinCEN No-Action Plan May Spur Crypto Innovation, In Theory

About Morrison Forester

people-default-header-desktop.jpg

people-default-header-mobile.jpg

Default Meta Data

Marc-Alain Galeazzi spoke to Law360 about the Financial Crimes Enforcement Network's (FinCEN) proposal to implement a no-action letter process."The no-action letter process would provide the market with some trust and comfort in what they're doing, whether it's legal or not, and whether they comply with legal requirements with regard to licensing, registration, and BSA and AML compliance," Marc-Alain said.He added that the goal of companies floating new products by FinCEN would ideally be to ensure they fall outside the bureau's anti-money laundering enforcement framework, which would require registration with FinCEN and also with almost every U.S. state."Most fintechs don't want to be a money transmitter," he said. "It's not because they want to circumvent any legal requirements, but because it's just very, very costly and cumbersome."Read the <a target="_blank" href="http:https://media2.mofo.com/v3/assets/blt5775cc69c999c255/blt6dd02fa3fd409974/62cdf741f1696e3810a03fd1/220615-fincen-no-action-plan-spur-crypto-innovation.pdf">full article</a>.