FinCEN recently issued non-binding guidance about the application of its guidance to virtual currencies, including bitcoin. There has been a good deal of chatter on social media about “what it all means,” but very little of it from lawyers with deep experience in payments and in the government, and even less with lawyers who have that experience as well as technical expertise. One of the few lawyers in the space who checks those boxes is my friend Steve Middlebrook, an Atlanta-based lawyer with the Womble Bond law firm. We were fortunate to get Steve to agree to answer some questions about the FinCEN guidance.
Stephen Palley: Tell us a little bit about yourself.