Banking Bitcoin-Related Businesses: A Primer for Managing BSA/AML Risks

This paper examines the current regulatory environment for Bitcoin-related businesses as well as measures these businesses can adopt to mitigate the BSA/AML risks inherent in the Bitcoin protocol. It also presents a framework for financial institutions (FIs) to consider for managing the risks associated with banking these companies. This paper is not a replacement, update, or supplement to BSA/AML guidance requirements provided in November 2014 by the Federal Financial Institutions Examination Council (FFIEC). By making a commitment to BSA/AML compliance, Bitcoin-related businesses can both better position Bitcoin as a mainstream payment system and enhance the ability of FIs to successfully bank them.