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

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."

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