On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) published FIN-2019-G001, which provides new guidance on the application of the Bank Secrecy Act (BSA) and FinCEN regulations to money services businesses that engage in money transmission involving convertible virtual currencies. While stating that it “does not establish any new regulatory expectations or requirements,” the guidance consolidates existing guidance, and in some areas applies the existing guidance to common business models and activities in…