J. Dax Hansen

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Decentralized Virtual Currencies



Perkins Coie attorneys regularly contribute to the Virtual Currency Report  which offers insight on the complex regulatory, enforcement, investment and consumer protection issues arising in the virtual currency ecosystem.

Bitcoin and other decentralized virtual currencies are quickly becoming a major force in online payments. However, decentralized virtual currencies raise complex regulatory and consumer protection issues. Perkins Coie is working with industry participants to navigate these complex issues.

Recent government enforcement actions by the Department of Justice, Office of Homeland Security, IRS, Secret Service, SEC and various state agencies, recent guidance issued by the U.S. Financial Crimes Enforcement Network (FinCEN), which asserts that businesses using virtual currencies might be engaged in money transmission activity, suggest that the government intends to apply long-standing, wide-ranging and hard-to-interpret money services business laws to the virtual currency industry. In light of the complicated legal landscape and the high stakes involved with noncompliance, individuals and companies connected to the virtual currency ecosystem should promptly seek guidance.

Perkins Coie, with our long history representing Internet and technology leaders, is at the front lines of these issues – helping clients navigate the thorny challenges faced by bitcoin and other virtual currency businesses.

Perkins Coie provides regulatory investigations and compliance counseling, litigation support, consumer protection counseling, and business transaction assistance, regarding a range of bitcoin and digital currency systems, services and products. Our clients include virtual currency exchanges, payment processors, investors, and industry associations.

We counsel virtual currency industry clients with respect to various regulatory issues, including compliance with the Bank Secrecy Act, FinCEN regulations, and securities and commodities laws and regulations. We help them draft anti-money laundering policies and organize their internal policies and practices for compliance. We have also assisted these clients in responding to inquiries from federal and state law enforcement and regulatory agencies. Our experienced investigations and white collar defense group regularly defends corporate clients and individuals against criminal and civil allegations of fraud, money laundering and other misconduct. Our defense practice includes particular experience in defending clients and property against government asset seizures and forfeitures.

Areas of Emphasis

  • Money Transmitting Licensing
  • Money Services Business Compliance
  • Business Operations
  • Privacy
  • Securities and Commodities 
  • Federal and State Investigations
  • Grand Jury Investigation
  • Litigation (Government Asset Seizures and Forfeitures)
  • Unfair Competition, Consumer Protection, and Antitrust
  • Congressional Hearings