Please join us for a webinar about significant anti-money laundering (AML) developments affecting technology companies. Panelists will include a representative from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), a primary anti-money laundering regulator, as well as an industry representative and Wilson Sonsini anti-money laundering lawyers.

Discussion topics will include:

• An explanation of why technology companies, particularly e-commerce, fintech, and gaming companies, are potentially subject to anti-money laundering (AML) regulations.
  • These AML regulations, including registration requirements, can apply to businesses that transmit funds, exchange currencies, or issue or sell virtual currencies, gift certificates, or other stored value (including in-game currencies).
  • AML regulators, especially the Treasury Department’s Financial Crimes Enforcement Network (FinCEN), are increasingly focused on AML regulations for technology companies, and new regulations are pending that may make compliance more burdensome.
• Further, the Anti-Money Laundering Act of 2020 will, when implemented in 2022, require beneficial ownership filings for a large number of LLCs and corporations. Perhaps of greater importance, this new law likely will infuse FinCEN with far greater resources to ensure compliance with not only the new beneficial ownership requirements, but also existing AML requirements that have not, to date, been the subject of much enforcement activity.
• Compliance burdens may be avoidable for some companies or discharged with reasonable resources by others, but understanding the rules is a prerequisite for either path.