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Legal and Regulatory Developments Arising From the Growth of Cryptocurrency

By Kaimee Tankersley, Ashley R. Davis and Alexandra G. Ah Loy

With the rise of the popular bitcoin, there have been increasing questions regarding the legal, tax and regulatory implications for virtual currencies. Some courts have ruled that digital currency (virtual currency or cryptocurrency), including bitcoins, is “funds” or “money,” thus bringing it within the ambit of federal criminal statutes and, more broadly, the Commerce Clause of the United States Constitution.1 “Blockchain” refers to the technology underlying cryptocurrencies.

Blockchain is a distributed ledger, or a database that is shared and synchronized among a number of users. It is referred to as a distributed ledger because it exists on thousands of computers running the same software, required for a transaction to occur, creating a network where each computer is considered a “node.” In order for a transaction to take place, the transacting parties must be authenticated with “cryptography.” When a transaction is entered in the blockchain ledger, there is a consensus mechanism which requires a majority of the nodes in the network to validate the transaction data’s authenticity, decreasing the likelihood of fraud.2 Once the transaction is recorded, it is irreversible.

While the irreversible nature of the transaction can lead to other issues (such as forking, discussed later in this article), such irreversibility also builds trust in the technology and the transaction, reducing the need for trust in the transacting parties themselves. While financial supervisory authorities generally have not been required with blockchain, in lieu of such oversight, some companies have instituted exchange platforms and brokerage servers, among other things, effectively limiting the usage of blockchains to private service agreements.3

Additionally, due to the potential for civil and criminal liability related to misuse of digital currency, state and federal agencies have issued warnings to consumers and investors about the risks of virtual currencies. Among these warnings are the unclear cost of digital currencies, volatile exchange rates, the threat of hacking and scams and the lack of protection for lost or stolen funds. Similar concerns have also prompted increasing regulatory efforts.4

For example, in 2013 the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN), the agency charged with implementing the Bank Secrecy Act (BSA),5 issued an interpretive guidance in an attempt to bring clarity and certainty to one aspect of the regulation of virtual currencies.6 The FinCEN guidance explains that administrators and exchangers of virtual currency are money transmitters under existing regulations, and thus must register with FinCEN, keep particular records and report suspicious transactions to adequately guard against money laundering and terrorist financing abuse.7 FinCEN’s guidance therefore makes it clear the finance regulatory intent was to focus on individuals facilitating “the entry and exit into a convertible virtual currency system.”8 Also, since August 2014, consumers who have encountered a problem with digital currency products or services have been able to submit complaints to the U.S. Consumer Financial Protection Bureau (CFPB) to seek redress.9

Since FinCEN issued its guidance, dozens of participants in virtual currency arrangements (exchangers and administrators) have registered with FinCEN. FinCEN has also received an increasing number of suspicious activity reports (SARs) from these entities. While it is encouraging to see players in the virtual currency industry appreciating such responsibilities and modifying their businesses to comply with these transparency requirements, there are still many virtual currency exchangers and administrators who have not registered with FinCEN and are failing to fulfill their recordkeeping and reporting requirements. By failing to comply with the FinCEN rules and regulations, these entities are putting themselves at risk of future legal or criminal consequences. Not only are they subject to FinCEN’s civil monetary penalties, but a knowing failure to register a money transmitting business with FinCEN – failure to register with state authorities when required – could constitute a federal criminal offense.10

The Commodity Futures Trading Commission approved the CME Group (owner of the Chicago Mercantile Exchange) to start trading bitcoin futures on Dec. 18, 2017, marking the first time bitcoin would be traded on a Wall Street exchange and subject to federal oversight. To ensure compliance with federal regulations, the CME Group implemented a process known as a “self-certification,” which is when an exchange pledges that the new instruments will not break any federal securities laws.11

On Dec. 11, 2017, Securities and Exchange Commission (SEC) Chairman Jay Clayton issued a strong statement on cryptocurrencies and initial coin offerings to urge market professionals, including attorneys, to peruse the SEC’s 21(a) Report and subsequent enforcement actions in which the SEC “applied longstanding securities law principles to demonstrate that a particular token constituted an investment contract and was therefore a security under our federal securities laws.”12 SEC Chairman Clayton further noted that, in its 21(a) Report, the SEC “concluded that the token offering represented an investment of money in a common enterprise with a reasonable expectation of profits to be derived from the entrepreneurial or managerial efforts of others.”13 With regard to market participants who have failed to analyze the applicability of securities laws to digital currencies, Chairman Clayton offered strong caution:

Selling securities generally requires a license, and experience shows that excessive touting in thinly traded and volatile markets can be an indicator of “scalping,” “pump and dump” and other manipulations and frauds. Similarly, I also caution those who operate systems and platforms that effect or facilitate transactions in these products that they may be operating unregistered exchanges or broker-dealers that are in violation of the Securities Exchange Act of 1934.

On cryptocurrencies, I want to emphasize two points. First, while there are cryptocurrencies that do not appear to be securities, simply calling something a “currency” or a currency-based product does not mean that it is not a security. Before launching a cryptocurrency or a product with its value tied to one or more cryptocurrencies, its promoters must either (1) be able to demonstrate that the currency or product is not a security or (2) comply with applicable registration and other requirements under our securities laws. Second, brokers, dealers and other market participants that allow for payments in cryptocurrencies, allow customers to purchase cryptocurrencies on margin, or otherwise use cryptocurrencies to facilitate securities transactions should exercise particular caution, including ensuring that their cryptocurrency activities are not undermining their anti-money laundering and know-your customer obligations. As I have stated previously, these market participants should treat payments and other transactions made in cryptocurrency as if cash were being handed from one party to the other.

Thus, the SEC’s position is clear that cryptocurrency should be generally treated no differently than other tangible currency. While calling for vigorous policing of cryptocurrency and enforcement action on violators, Chairman Clayton concluded that, “[b]y and large, the structures of initial coin offerings that I have seen promoted involve the offer and sale of securities and directly implicate the securities registration requirements and other investor protection provisions of our federal securities laws. Generally speaking, these laws provide that investors deserve to know what they are investing in and the relevant risks involved.”14

However, there remains a lack of clarity over what specific regulations currently apply – and to what extent they apply – to cryptocurrency. On Jan. 18, 2018, the SEC issued a staff letter addressing issues arising from funds potentially focused on cryptocurrency-related products. In the letter, the director of the Division of Investment Management (DIM) of the SEC explored the implications of the Investment Company Act of 1940 (1940 Act) upon cryptocurrency. DIM Director Blass explained that the 1940 Act’s intent was to impose “safeguards to ensure that registered funds maintain custody of their holdings.”15 The rise of cryptocurrency has created new questions related to compliance with the 1940 Act. For example, uncertainty arises when a fund plans to hold cryptocurrency directly, as there had been no reported custodians providing fund custodial services for cryptocurrencies. Further, there are related concerns over the constraints for such a fund to be able “to validate existence, exclusive ownership and software functionality of private cryptocurrency keys and other ownership records.”16 Moreover, it is still unclear what adequate safeguards can be implemented under the 1940 Act to protect against cybersecurity threats and hacks on digital wallets. After a focused analysis over the uncertainty regarding how to properly regulate cryptocurrency, including accounting, audit and reporting requirements and compliance with the Securities Act of 1933, Director Blass concluded that:

Until the questions identified above can be addressed satisfactorily, we do not believe that it is appropriate for fund sponsors to initiate registration of funds that intend to invest substantially in cryptocurrency and related products, and we have asked sponsors that have registration statements filed for such products to withdraw them. In addition, we do not believe that such funds should utilize rule 485(a) under the Securities Act, which allows post-effective amendments to previously effective registration statements for registration of a new series to go effective automatically. If a sponsor were to file a post-effective amendment under rule 485(a) to register a fund that invests substantially in cryptocurrency or related products, we would view that action unfavorably and would consider actions necessary or appropriate to protect Main Street investors, including recommending a stop order to the Commission.17

Thus, there remains uncertainty as to the applicability of current regulations to virtual currency. While other agencies may have uncertainty regarding cryptocurrency, the Internal Revenue Service has made it very clear that virtual currency transactions are taxable just as any other property transaction.18 The consequences of not reporting can include the tax due with interest and penalties, and, in more extreme cases, possible criminal charges for tax evasion and filing a false tax returne, both of which carry a prison term and fine of up to $250,000 each.19

With China, South Korea and India paving the way to establishing broad-reaching regulatory frameworks over virtual currency, it would seem federal regulation in the United States is imminent. In fact, on Feb. 6, 2018, the Senate Banking Committee held a promising hearing about the need for oversight of digital currencies.20

STATE REGULATION AS OF NOVEMBER 201721
In the absence of clear federal law on the implications and regulation of cryptocurrency, state governments have begun enacting their own statutory and/or administrative frameworks for regulating cryptocurrency and safeguarding against its attendant risks. While many states have remained silent, several states have enacted some form of blockchain laws. These state laws have taken a variety of forms but do share some common themes.

Some states, such as Alabama, have enacted laws requiring persons engaging in monetary transmission, including through virtual currency, to obtain licensure unless otherwise exempted.22Similarly, the Texas Department of Banking issued a supervisory memorandum in 2014 stating that cryptocurrency is not “money” under its Money Services Act, concluding that “[b]ecause neither centralized virtual currencies nor cryptocurrencies are coin and paper money issued by the government of a country, they cannot be considered currencies under Texas’s statute.” However, the memorandum made clear the position that “[a] cryptocurrency business that conducts money transmission must comply with all applicable licensing provisions of [Texas’s Finance Code and Administrative Code].”23

Arizona has specifically codified the legal effect, validity and enforceability of “smart contracts.”24Other state legislation has been enacted to address recordkeeping for trading corporate stock via electronic networks.25 Additionally, California has proposed active legislation to create a Digital Currency Business Enrollment Program that would require digital currency business to pay a nonrefundable fee to participate.26

Other states have passed legislation to address the concerns regarding secured and unsecured lending in cryptocurrencies. For example, Connecticut passed a statute requiring that “[e]ach licensee that engages in the business of money transmission in this state by receiving, transmitting, storing or maintain custody or control of virtual currency on behalf of another person shall at all times hold virtual currency of the same type and amount owed or obligated to such other person.”27

In July 2017, North Carolina amended its Money Transmitter Act to define virtual currency as a medium of exchange but which does not have tender status recognized by the United States government. 28 North Carolina’s act applies not only to money transmission but also to transactions conducted in whole or in part in virtual currency. The act previously required a surety bond, but now, due to cybersecurity risks inherent in virtual currency and the applicant’s business model, the commissioner has been vested with discretion to require additional insurance coverage.29Moreover, states such as Florida and West Virginia have amended their laundering statutes to specifically include virtual currency as monetary currency.30

Some states have also begun enacting legislation directed at the ownership and tax implications of virtual currency. For example, New Jersey passed legislation expressly authorizing an estate’s executor under certain circumstances to manage the digital assets, including virtual currencies, of a decedent.31 New Jersey’s Division of Taxation further addressed the issue of cryptocurrency taxation by issuing a technical advisory memorandum stating that New Jersey confirms to the federal tax treatment of virtual currency and, therefore, any transactions using virtual currency in a transaction for goods or services should be recorded in U.S. dollars at the date of payment or receipt, but that such cryptocurrency is treated as intangible property with respect to sales or use tax associated where the virtual currency is the subject of the transaction (and therefore is not subject to sales tax).32 In March 2017, Utah amended its Unclaimed Property Act to include virtual wallets and virtual currency.33

Other states have adopted broad regulatory frameworks in response to the emergence of cryptocurrency. For example, in 2015, the New York State Department of Financial Services established the BitLicense Regulatory Framework, which requires operations related to virtual currency transactions to obtain a license issued by the state. The New York framework provides that such licensees are required to maintain and enforce policies regarding anti-fraud, anti-money laundering, cybersecurity and privacy and information security, all of which must be reviewed and approved by a licensee’s governing body.34

Like New York, Washington has adopted a broad regulatory framework for virtual currency.35Washington’s statutory framework includes virtual currency within its definition of money transmission, over which it imposes strict regulations. Among other regulations, Washington’s Uniform Money Services Act requires virtual currency exchange operators to comply with the state’s money transmitter and licensing rules. With the passage of such stringent regulatory laws on virtual currency, it should be no surprise that virtual currency operators have begun shopping for states with friendlier laws for their market.

By way of contrast, some states, such as Nevada, have outright rejected any regulation or imposition of tax burdens upon cryptocurrency.36 Such legislation would in effect create an encouraging market for technology startups. Wyoming has also seen the formation of the Wyoming Blockchain Coalition, whose aim is to create cryptocurrency- and blockchain-friendly laws and regulations to encourage virtual business growth within the state of Wyoming.37

UNREGULATED STATES AS OF NOVEMBER 2017
Despite the rise of blockchains and cryptocurrency, many states have not yet enacted legislation. At the end of the state legislative sessions in 2017, most of the states, including Oklahoma, still had no blockchain laws enacted.38 However, even in the absence of specific legislation, many of those states’ regulatory agencies have issued opinion letters and memoranda addressing concerns over the interaction between cryptocurrency and state laws.39

In Oklahoma, there are currently no blockchain- or virtual currency-specific regulations. However, in 2014, Oklahoma’s Legislature added an official comment to its statute regarding transfers of money and transfers of funds from deposit accounts, 12A O.S. §1-9-332. The comment states:

As of mid 2014, the use of so called “bitcoins” and the like seem to be gaining traction as a form of “currency,” i.e., as a payment method. Apparently some sellers are willing and able to take bitcoins in payment for goods or services sold. If that payment instead were made in cash, or by a check out of a deposit account, any security interest in that cash or account as proceeds of the claim of a secured party that has a security interest in inventory would not impair the further use of the payment by the seller for payment of debt or other transfers to a third party. See UCC sections 9-332, 9-315(a)(2), (c) and (d). This is a consistent policy under UCC Article 9 -- see, for example, sections 9-320, and 9-321, and is particularly strong with respect to “currency.” However, section 9-332 cannot be construed to protect the receiver of bitcoins. Whether the policy mentioned above should allow a court to reach the same result remains a presently unanswered question.

Thus, while the Oklahoma Legislature has not formally enacted any statutory framework specific to virtual currencies or blockchains, the Legislature has made clear its position that a seller who accepts virtual currency does not take such virtual currency free of an existing security interest. It is also worth noting that in 2017 the Texas-based company Coinsource installed a bitcoin ATM in Oklahoma City, the first such machine to be installed Oklahoma.40

While some states had not yet passed legislation specific to virtual currency as of the end of their 2017 legislative sessions, several of those states’ regulatory agencies had issued warnings and guidance on virtual currency. For example, in Kansas, the Office of the State Bank Commissioner issued guidance on the applicability of the Kansas Money Transmitter Act to people or businesses transacting virtual currency.41 In Maryland, the Department of Labor, Licensing and Regulation issued a warning to consumers about the potential dangers of virtual currency.42 In Massachusetts, the Office of Consumer Affairs and Business Regulation issued an opinion letter which declared that “financial institutions” do not include bitcoin ATMs where traditional currency is inserted and a paper receipt is given or money is moved to a public key on a blockchain, but does not connect to a bank account.43 In Michigan, the Department of the Treasury addressed the application of sales tax with respect to virtual currency.44

Although there is no uniformity in virtual currency laws across the United States, the laboratories of democracy are beginning to respond to the demand for increased regulation, and the federal government is entertaining discussions of a broad regulatory framework. This is a novel and growing area of law that should excite lawyers, accountants and techies alike, as it will undoubtedly continue to create questions of law and compliance.

ABOUT THE AUTHORS
Kaimee Kellis Tankersley is a lecturer at the OU Price College of Business John T. Steed School of Accounting as well as managing member of Kellis Tankersley PLLC. Her work has been presented at conferences including the American Accounting Association Annual Conference and the Southern Academy of Legal Studies in Business.

Dr. Ashley R. Davis is an assistant professor at the OU Price College of Business John T. Steed School of Accounting. Her professional experience includes consulting on information systems and managing $2.5 billion in e-business. Her research has been published in journals such as MIS Quarterly Executive and Communications of AIS.

Alexandra G. Ah Loy is an associate attorney at the law firm of Johnson, Hanan & Vosler in Oklahoma City where she practices in civil litigation, including medical malpractice, civil rights defense and subrogation. Mrs. Ah Loy graduated with honors from the OCU School of Law in 2012.

1. See, e.g., United States v. Murgio, 209 F. Supp. 3d 698, 707 (S.D.N.Y. 2016); 18 U.S.C. §1960; U.S. Const. art. I, §8, cl. 3.
2. Benjamin Wallace, “The Rise and Fall of Bitcoin,” Wired Magazine (Nov. 23, 2011, 2:25 p.m.),www.wired.com/2011/11/mf_bitcoin/.
3. Volker Brühl, “Virtual Currencies, Distributed Ledgers and the Future of Financial Services,” Intereconomics, Vol. 52, Iss. 6, 370-378 (November 2017).
4. See, e.g., Statement on Cryptocurrencies and Initial Coin Offerings (Dec. 11, 2017), available at www.sec.gov/news/public-statement/statement-clayton-2017-12-11; Press Release, Consumer Finance Protection Bureau, CFPB Warns Consumers About Bitcoin (Aug. 11, 2014) (on file with author); N.C. Office of the Comm’r of Banks, Consumer Alert: Virtual Currencies (on file with author); F.L. Chief. Fin. Officer, Consumer Alert: Virtual Currencies (March 18, 2014) (on file with author); C.A. Dep’t of Bus. Oversight, What You Should Know About Virtual Currencies (April 14, 2014) (on file with author); Press Release, U.S. Dep’t of the Treasury, Remarks from Under Secretary of Terrorism and Financial Intelligence David S. Cohen on “Addressing the Illicit Finance Risks of Virtual Currency” (March 18, 2014) available at www.treasury.gov/press-center/press-releases/Pages/jl236.aspx.
5. The Bank Secrecy Act (BSA), 31 U.S.C. §5311, et seq., also known as the Currency and Foreign Transactions Reporting Act, is the primary U.S. anti-money laundering law.
6. U.S. Dep’t of the Treas., FinCEN, FIN-13-G001, Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies (March 18, 2013).
7. Press Release, Consumer Finance Protection Bureau, CFPB Warns Consumers About Bitcoin (Aug. 11, 2014).
8. Id.; Press Release, U.S. Dep’t of the Treasury, Remarks from Under Secretary of Terrorism and Financial Intelligence David S. Cohen on “Addressing the Illicit Finance Risks of Virtual Currency” (March 18, 2014) available at www.treasury.gov/press-center/press-releases/Pages/jl236.aspx.
9. Press Release, Consumer Finance Protection Bureau, CFPB Warns Consumers About Bitcoin (Aug. 11, 2014).
10. Id.
11. Ken Sweet, “Federal Regulator Gives OK for Bitcoin Futures to Trade,” U.S. News, Dec. 1, 2017; see, also, National Cybersecurity Awareness and Education Program, 15 U.S.C. §7451(b).
12. Statement on Cryptocurrencies and Initial Coin Offerings (Dec. 11, 2017), available at www.sec.gov/news/public-statement/statement-clayton-2017-12-11.
13. Id., with reference to Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DA (July 25, 2017), available at www.sec.gov/litigation/investreport/34-81207.pdf
14. Id.
15. U.S. Securities and Exchange Commission, staff letter: Engaging on Fund Innovation and Cryptocurrency-related Holdings (Jan. 18, 2018), available at www.sec.gov/divisions/investment/noaction/2018/cryptocurrency-011818.htm; Investment Company Act of 1940, 15 U.S.C. §80-1, et seq.
16. Staff letter, id.
17. Id.
18. Notice 2014-21, 2014-16 I.R.B. 938, available at www.irs.gov/pub/irs-drop/n-14-21.pdf.
19. IRS reminds taxpayers to report virtual currency transactions, IRB News Release, IR-2018-71 (March 23, 2018), available atwww.irs.gov/newsroom/irs-reminds-taxpayers-to-report-virtual-currency-transactions.
20. U.S. Securities and Exchange Commission, Chairman’s Testimony on Virtual Currencies: The Roles of the SEC and CFTC (Feb. 6, 2018), available at www.sec.gov/news/testimony/testimony-virtual-currencies-oversight-role-us-securities-and-exchange-commission.
21. The authors note this article addresses the status of cryptocurrency laws as they existed at the end of November 2017. Because this is a quickly changing area of law, there are likely to have been more recent enactments and developments since the date of this article’s drafting.
22. See Alabama Monetary Transmission Act, Ala. Code §8-7A-1, et seq.
23. T.X. Dep’t of Banking, Supervisory Memorandum – 1037: Regulatory Treatment of Virtual Currencies Under the Texas Money Services Act (April 3, 2014), available at www.dob.texas.gov/public/uploads/files/consumer-information/sm1037.pdf.
24. See Arizona’s “Blockchain Technology” statute, A.R.S. §44-7061 (2017).
25. See Del. Code Ann., tit. 8, §224.
26. See 2017 California Assembly Bill No. 1123, California 2017-2018 Regular Session.
27. Conn. Gen. Stat. Ann. §36a-603; see, also, Conn. Gen. Stat. Ann. §36a-596(16) (defining “virtual currency” as “any type of digital unit that is used as a medium of exchange or a form of digitally stored value or that is incorporated into 
a payment system technology”).
28. N.C. Gen. Stat. §§53-208.41, et seq.
29. See N.C. Gen. Stat. §§53-208.42(20), 53-208.44-47.
30. Fla. Stat. §896.101. The authors note this amendment appears to have been in response to a Florida court dismissal of two counts of money laundering against a defendant based upon its ruling that Bitcoin is not “money” within the plain reading of Florida’s money laundering statute. See State v. Espinoza, No. 14-cr-2923, motion to dismiss granted (Fla. Cir. Ct., Miami-Dade Cty., July 22, 2016). See also, W. Va. Code Ann. §61-15-1(8).
31. N.J. Stat. §3B:14-61.1, et seq.; see also Virginia’s Uniform Fiduciary Access to Digital Assets Act, Va. Code Ann. §§64.2-116,et seq.
32. N.J. Div. of Taxation, Technical Advisory Memorandum 2015-1(R): Convertible Virtual Currency (July 28, 2015), available atwww.state.nj.us/treasury/taxation/pdf/pubs/tams/tam-2015-1.pdf.
33. See Utah Code Ann. §67-4a-102(28)(b)(ii)(A) and (35).
34. N.Y. Comp. Codes R. & Regs. tit. 23, §§200.1, et seq.
35. See Uniform Money Services Act, Wash. Rev. Code §§19.230.900, et seq.
36. See Nev. Rev. Stat. §SB 398, §6 (Restrictions on incorporated cities regarding blockchains).
37. Amy Castor, “Blockchain Coalition Seeks to Make Bitcoin Welcome in Wyoming,” Bitcoin Magazine, Nov. 17, 2017.
38. These states include Arkansas, Colorado, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, New Mexico, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee and Wisconsin.
39. See, e.g., I.D. Dep’t of Fin., Idaho Money Transmitter No-Action and opinion letter (Oct. 11, 2017), available atwww.finance.idaho.gov/MoneyTransmitter/Documents/NAOP/Digital%20Currency/2017-10-11.pdf; I.L. Dep’t of Fin. & Prof’l Reg., Illinois Dept. of Financial and Professional Regulation, Digital Currency Regulatory Guidance (June 13, 2017), available atwww.idfpr.com/Forms/DFI/CCD/IDFPR%20-%20Digital%20Currency%20Regulatory%20Guidance.pdf
40. Abby Bitterman, “Oklahoma Gets Its First Bitcoin ATM,” NewsOK, July 9, 2017, available at newsok.com/article/5558128
41. K.S. Off. Of the State Bank Comm’r, Guidance Document MT 2014-01: Regulatory Treatment of Virtual Currencies under the Kansas Money Transmitter Act (June 6, 2014), available atwww.osbckansas.org/mt/guidance/mt2014_01_virtual_currency.pdf.
42. M.D. Dep’t of Labor, Lic. & Reg., Comm’r of Finan. Reg., Advisory Notice: Virtual Currencies: Risks for Buying, Selling, Transacting, and Investing (April 24, 2014), available at www.dllr.state.md.us/finance/advisories/advisoryvirtual.pdf.
43. M.A. Div. of Banks, Selected Opinion Letter 14-004: Bitcoin Kiosks Licensure or Registration Requirements (May 12, 2014), available at www.mass.gov/opinion/selected-opinion-14-004-0; Volker Brühl, “Virtual Currencies, Distributed Ledgers and the Future of Financial Services,” Intereconomics, Vol. 52, Iss. 6, 370-378 (November 2017).
44. M.I. Dep’t of Treas., Tax Policy Div., Treasury Update: Offer-in-Compromise Program Provides Relief for Taxpayers, Vol. 1, Iss. 1 (November 2015).

Originally published in the Oklahoma Bar Journal -- OBJ 89 pg. 18 (May 2018)