FinCEN Issues Notice on Convertible Virtual Currency Kiosks
In August, FinCEN issued a Notice urging financial institutions to be on the lookout for convertible virtual currency kiosks (sometimes referred to as CVC kiosks or cryptocurrency ATMs) that may be used for scam payments and/or to launder drug and other illegal proceeds. FinCEN has seen an increase in scammers and Transnational Criminal Organizations (TCOs) using CVC more frequently, in order to expedite funds transfers and make it difficult for law enforcement to recover the funds.
The Notice provides a listing of 15 red flags that kiosk operators and other financial institutions are urged to look for, which includes red flags that could indicate a CVC owner or operator is not complying with applicable regulations. Many of the red flags are related to transactions just below reporting thresholds, kiosk daily limits or kiosk owners/operators that require little or no information in order to conduct transactions.
FinCEN asks that SARs filed on activity related to this Notice include FIN-2025-CVCKIOSK in SAR Field 2 (Filing Institution Note to FinCEN as well as the Narrative.
Diane Dean
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!