” Exchanging bitcoin on behalf of ransomware victims should not be construed as criminal activity by the exchanger, not as a matter of law nor as sound policy. Such an interpretation would set a precedent that would surely cause real harm to the public, to the blockchain ecosystem, and to the financial services industry as a whole. “


” Applying criminal law to the exchange of bitcoin on behalf of ransomware victims would create a morally shocking result of re-victimizing a victim. All lawfully operating digital currency exchanges would thereafter refuse to exchange bitcoin for ransomware victims for fear of criminal culpability. “


” FinCEN directs financial institutions to file suspicious activity reports (SARs) to inform law enforcement of certain types of cyber-enabled crime. As the agency charged with protecting the United States from financial crime, FinCEN’s guidance does not deem financial institutions who process such transactions to be involved in a criminal activity. “


” The law provides a remedy, charging those who threaten a victim’s data for the purpose of extortion. Extending criminal liability to innocent third-party digital currency exchangers, or any other third-party financial institution, would be an utterly unwarranted and unjust misinterpretation both of law and policy. “



All 4 Perianne Boring Quotes about Law in picture


Exchanging bitcoin on behalf of ransomware victims should not be construed as criminal activity by the exchanger, not as a matter of law nor as sound policy. Such an interpretation would set a precedent that would surely cause real harm to the public, to the blockchain ecosystem, and to the financial services industry as a whole.
Applying criminal law to the exchange of bitcoin on behalf of ransomware victims would create a morally shocking result of re-victimizing a victim. All lawfully operating digital currency exchanges would thereafter refuse to exchange bitcoin for ransomware victims for fear of criminal culpability.


FinCEN directs financial institutions to file suspicious activity reports (SARs) to inform law enforcement of certain types of cyber-enabled crime. As the agency charged with protecting the United States from financial crime, FinCEN
The law provides a remedy, charging those who threaten a victim
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