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Podcast: Impact of FRB and FinCEN Proposed Amendments to Recordkeeping and Travel Rule Regulations

Client Alert | less than 1 min read | 01.22.21

On October 23, 2020, the Federal Reserve Board and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking that would amend the Bank Secrecy Act’s Recordkeeping Rule and Travel Rule regulations. The proposed changes would: (a) lower the threshold for covered cross-border transactions from $3,000 to $250, and (b) extend the applicability of the rules to convertible virtual currency and digital assets. Caroline Brown moderates this panel discussion hosted by KPMG and Carlton Greene provides insight into what the changes mean for virtual currency companies and payments companies. 

Click here to listen to this podcast on KPMG's site.

Insights

Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....