On April 18, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury announced the assessment of a civil money penalty against Eric Powers for willfully violating the registration, program and reporting requirements of the Bank Secrecy Act and its implementing regulations. Between December 2012 and September 2014, Mr. Powers acted as a peer-to-peer (“P2P”) currency exchanger of convertible virtual currency, conducting activities that qualified as money transmission, as defined in 31 C.F.R § 1010.100(ff)(5), and were therefore subject to BSA obligations. This is FinCEN’s first enforcement action against a P2P virtual currency exchanger and the first time FinCEN has penalized a virtual currency exchanger for failure to file Currency Transaction Reports.
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