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Bitcoins and SAR Narratives



          July 24, 2014


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You probably know about Bitcoin, unless you have been living in total seclusion for that last few years. The big controversy usually centers on determining if it is legal tender. 


 

But imagine if you are confronted with a transaction involving Bitcoin.


 

Do you file a Suspicious Activity Report ("SAR")?


 

It so happens that the Financial Crimes Enforcement Network ("FinCEN") has been giving that very concern laser-like attention! In July 2014's "SAR Stats," FinCEN observed that the "rapid adoption and price fluctuation of Bitcoin" has put convertible virtual currencies in the spotlight over the past year. 


 

The same attributes of virtual currencies that attract lawful users, such as the capacity for anonymity as well as their speed and global reach, attract criminal actors engaged in illicit financing. 


 

FinCEN is observing a rise in the number of SARs flagging virtual currencies as a component of suspicious activity. 


 

Bitcoin is considered one of the emerging payment methods. 


 

Consequently, it is important to understand virtual currencies in order to properly complete the SAR Narrative.


 

In this article, I provide an outline of FinCEN's perspective on the Bitcoin virtual currency. 

 
Best wishes,
Jonathan Foxx
President & Managing Director

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