Well, it was another quiet month in crypto . . . Not. We are still watching the tsunami play out in real time, as governments and the crypto market react to another seismic shift in the crypto landscape. While events of the last month raise numerous important questions, our focus here is on the issues affecting financial services companies, particularly Fintechs and crypto-involved companies, that continue to build and develop compliance-focused platforms. The path ahead remains open, but, more than ever, it’s critical to stay ahead of the enforcement issues that are on the horizon.
- The CFPB’s Deep Dive on Crypto Consumer Complaints
- DOJ’s November Crypto Enforcement Hits
- Tornado Cash Part III – The Saga Continues
- The OCC and SEC Remain Vigilant Against Individuals
- What Happens When FinCEN Assesses a Penalty And the Subject Doesn’t Pay?
Bonus: OFAC’s Kraken Action Emphasizes Ongoing Monitoring
1. The CFPB’s Deep Dive on Crypto Consumer Complaints
Individual Penalties by Regulatory Agency
(2018-Present)
On November 10th, the CFPB issued a 45-page “Complaint Bulletin” describing and analyzing crypto-asset-related complaints submitted by individual consumers through the Bureau’s complaint portal. Although the CFPB itself has yet to issue a crypto-specific rule or bring an enforcement action involving digital assets, it plays a key role in collecting consumer complaints and providing thought leadership to the federal and state regulators who may be…
