Now that virtual/digital currency dealers and brokers are required to obtain both FinCEN, as well as state, money service business licenses, and those who fail to do so are being targeted, you should review your existing accounts, to determine whether you are banking any company or individual in the virtual currency industry. hint: they may be harder to identify than you think.
Since was an unregulated activity, prior to the FinCEN ruling, participants in this unconventional method of finance may have resorted to subterfuge to appear to be something else entirely. Though this is a relatively new class of payment system, virtual currency brokers and traders must, initially at least, exchange dollars for virtual funds. That is how you will probably identify them.
Do you have any clients whose lines of business involve barter, or exchanges of some sort ? These may be cleverly-disguised virtual funds dealers. Any new clients with substantial business that doesn't seem to fit into any known category ? Though there are no established red flags for identifying virtual currency companies, any unusual or unconventional bank client could be one, and in performing a search, you just may find some whose accounts involve financial crime, in the process.
Whilst we are certainly not targeting the virtual or digital currency industry, since it is is totally unregulated, it does, at this time, qualify as high risk for financial institutions that choose to process its payments, especially since the recent Liberty Reserve cash exposed the use of that company's facilities to facilitate payments for illegal services, and to move the proceeds of crime. Until and unless the virtual or digital currency business becomes effectively regulated, on a global basis, anyone dealing with it, in a business relationship, runs the risk of unwittingly assisting in money laundering, or a number of other financial crimes; be extremely careful here,