On April 18, 2019, the Financial Crimes Enforcement Network ("FinCEN") announced its first enforcement action against a peer-to-peer virtual currency exchanger. See FinCEN Penalizes Peer-to-Peer Virtual Currency Exchanger for Violations of Anti-Money Laundering Laws, Fin. Crimes Enforcement Network (April 18, 2019) [hereinafter FinCEN Release], https://www.fincen.gov/news/news-releases/fincen-penalizes-peer-peer-virtual-currency-exchanger-violations-anti-money. The enforcement action was against Eric Powers ("Powers") for violations of the Bank ...
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