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World Money Laundering Report Volume 12 Number 3

Digital Dollars, Virtual Payments, Real World Risk and Regulation.

The risks and regulation of Bitcoin and other digital currencies.

In this issue

Box 1: What is Time Banking?
Trackability of bitcoins
Similarities between e-currencies and internet banking
Nothing stands still for long.
Is a psychological shift removing scepticism?
Bitcoin is a disruptive technology
Bitcoins in your pocket: Mondex 20 years on?
Bitcoin: going mainstream for SMEs abandoned by Google Checkout?
Some participators in Bitcoin may be regarded as deposit taking.
Bitcoin Mining
Interfacing virtual and real world currencies.
USA v Dwolla, Governments and banks v Bitcoin Exchanges.
Can Bitcoins be considered an investment product?
Box 2: The word's biggest e-currency - the euro.
Box 3. A "private" currency is not "foreign" currency.
Is dealing in Bitcoin futures a regulated activity?
Bitcoin bubbles - fact or fantasy?
Can Bitcoins be pumped and dumped?
Non-bank issuers of electronic money.
BOX 4: European Banking Authority: defining e-money issuer, agent, distributor
Could there be a "run" on Bitcoin?
What is a Bitcoin exchange?
Bank secrecy / confidentiality
Data Security
Regulating Silicon (Valley) Money
e-money issuers: capital adequacy issues
Who owns Bitcoin?
It's called what?
Where are bitcoins stored?
Box 5: The Liberty Dollar case: a red herring?
Is Bitcoin developing in a responsible manner?
Can regulators shut down the service?
- Legislation / Regulation
- Direct action
- Indirect action
Bitcoin as a vehicle for financial crime
Bitcoin and the USA PATRIOT Act 2011, s311
How does Bitcoin work?
Non-legislative / law enforcement threats to Bitcoin
Keeping eyes on the money
Do Bitcoin and other e-currencies have the potential to undermine economies?
What are the risks for banks?

Published in the UK by Vortex Centrum Ltd, www.vortexcentrum.com.
ISSN: 1473-3439

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Bitcoin is in the news but it is only the latest of a long line of alternative currencies. However, the surge of interest in Bitcoin over a very short period of time means that, at present, it does appear to be the most likely to succeed in gaining a critical mass.

However, all e-currencies create a range of risks from systemic risk to economies to regulatory and financial crime risk. These affect populations at large, governments and banks and other financial institutions as well as all those subject to counter-money laundering law and regulation.

Nigel Morris-Cotterill, Head, The Anti Money Laundering Network, first examined the question of e-currencies, private currencies and alternative payment methods in the mid 1990s and has tracked their development, use and failures since.

In this issue of World Money Laundering Report, he examines the regulation, financial and economic risk management issues issues that arise as Bitcoin gains wider acceptance.

Inter alia, his paper draws out the distinction between "money" for currency purposes and "money" for counter-money laundering and anti-terrorist financing purposes (AML/CFT/CTF)

Bitcoin, virtual currency, digital dollars, Hong Kong, Monetary Authority, HKMA, Bank of Curacao, Russian, émigrés, VAT, carousel fraud, Florida, European Bank, Mondex, electronic cash, e-cash, ecash, wallet, pre-paid cards, gift-cards, time-banks, time is money, USA PATRIOT Act, bitcoin mining, FinCEN, Treasury, OFAC, security, stolen bitcoins, Mt.Gox, speculation, hacktivist, LulzSec, anonymous, Liberty Reserve, John Matthewson, Money Transmitter, MSB, money transmission, Bitcoin Foundation, California, Department of Financial Institutions, The California Department of Business Oversight, payable-through accounts, pass through accounts, market manipulation, market abuse, money laundering, fraud, terrorist financing, AML, CFT, declaration at borders, e-currency, supervision, oversight, Guam, Eastern Caribbean Dollar, rouble, I promise to pay the bearer

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