On February 13, 2018, the Financial Crimes Enforcement Network (FinCEN) released a letter to Senator Ron Wyden, a member of the Senate Committee on Finance, which made clear that virtual currency exchangers and administrators are money transmitters and must comply with the Banking Secrecy Act. Additionally, FinCEN indicated that it would be working closely with the U.S. Securities and Exchange Commission and the Commodity Futures Trading Commission to monitor initial coin offerings (ICOs). In this video, Jeffrey Alberts, Co-Chair of Pryor Cashman’s FinTech and Financial Institutions Group, discusses how FinCEN’s letter impacts companies who have been operating in this space but haven’t registered as money service businesses, and what virtual currency exchangers need to know when pursuing an ICO.