diff --git a/regulatory history - egold b/regulatory history - egold new file mode 100644 index 0000000..43408ba --- /dev/null +++ b/regulatory history - egold @@ -0,0 +1,483 @@ +Regulatory History +Abstract: Regulatory action against digital currency +systems started quietly in Australia in 2004. In 2005, e-gold +was raided but no charges were filed. In 2007, GoldAge, one +of the original exchange agents, was closed and prosecuted. +Also in 2007, the e-gold operators were indicted on multiple +felony charges and the assets of about a dozen exchange +agents in America were seized. Similar actions to separate +digital currency businesses from US banking faculties can +be seen today in the operation of US Bitcoin businesses. +Mullan, Carl P. The Digital Currency Challenge: +Shaping Online Payment Systems through US Financial +Regulations. New York: Palgrave Macmillan, 2014. +DOI: 10.1057/9781137382559.0008. +Regulatory History  +DOI: 10.1057/9781137382559.0008 +The question of regulating digital currency at the federal level and +requiring state licensing dates back more than ten years. In 2002, early +digital currency operators were unaware if their companies required +licensing. Mr. James Fayed, the operator of e-bullion.com and owner +of Gold Finger Coin & Bullion, asked his corporate attorney to inquire +with the State of California requesting clarification if a money transmitting +license was required for the e-bullion.com business. The response +from state officials at that time was negative. In 2002, the attorney for +e-bullion.com was informed by the state that its business did not require +a California Money Transmitting License. “They are not eligible for a +money transmitter license because their business model was not taking cash +from person A and delivering cash to person B.”1 + With the popularity of +e-gold on the rise around the world, the governments of other countries +such as India were also taking notice of digital currency. In October +2002, the Reserve Bank of India (RBI) banned digital gold as a payment +channel in that country. Specific digital gold companies mentioned by +the government and included in this ban were e-gold and GoldMoney.2 +In September 2004, several Australian independent digital currency +exchanges ceased operation due to the strict application of Financial +Services Licensing regulations in that country. Digital gold currency +exchangers that were forced to close by the Australian Securities and +Investments Commission (ASIC) included: goldex.net, sydneygoldsales. +com, and ozzigold.com. While digital currency systems and these +exchange operations in Australia had not yet been legally defined by +government regulators, the ASIC believed digital currency products +could be defined as non-cash payment systems. In Australia, people who +deal in these products with Australian consumers are required to hold +an Australian financial services license (AFSL).3 +In 2004, in what was a friendly action by the Australian government, +there were no arrests and no seizures. The local Australian companies +all cooperated with ASIC throughout the investigation. Each exchange +operation voluntarily withdrew company websites and closed businesses. +The independent exchange agents operating in Australia simply moved +to other jurisdictions and continued business under a different name or +sold the business to associates in other countries. Australia’s new regulations +had no long-term effect on e-gold liquidity or the digital currency +industry. Since the online digital currency marketplace was global, +Australian digital currency consumers simply continued transacting +business through other countries. For easy operation, some Australian + The Digital Currency Challenge +DOI: 10.1057/9781137382559.0008 +users even opened New Zealand-based bank accounts and transacted +their digital currency business through New Zealand. +The events which unfolded following this brief government response +in Australia, became a reactionary model for future digital currency +regulatory events. This has become a well-recognized trend in digital +currency. Due to the global nature of Internet digital currency, when one +environment, jurisdiction, or network becomes too regulated businesses +seeking to maintain their profitable enterprises, especially bad actors, +will simply change jurisdictions or platforms. This friendly action by the +Australian government in 2004 was the only large regulatory event to +take place prior to US law enforcement action against e-gold. +On the evening of December 19, 2005, agents with the Federal Bureau +of Investigation and Secret Service raided the Melbourne, Florida, office +of e-gold’s parent company, Gold & Silver Reserve Inc., and the local +residence of founder, Dr. Douglas Jackson. No arrests were made at that +time. That evening agents seized e-gold records, financial records, and +volumes of data. The information, seized by the Secret Service, pertained +to e-gold accounts, transaction information, electronic records, and other +documents. Agent James Glendinning from the Secret Service’s Orlando +office stated that “the 2005 raid was a spinoff of a 2004 international +crackdown on Internet identity thieves who had used e-gold to receive +payments.”4 + As a direct result of the 2005 seizure, a court order froze all +the US bank accounts of e-gold’s parent company. The December 2005 +raid temporarily crippled the e-gold operation due to its loss of access to +US bank accounts. +A similar situation is now occurring with Bitcoin. Since July 2011, +when the new MSB rule began to be implemented, US commercial banks +have withdrawn from digital currency activity. Banks, fearing regulatory +action and possible association with the illegal proceeds of crime, have +been turning away from companies dealing in Bitcoin. With the US +government’s seizure of Wells Fargo and Dwolla accounts, Mt. Gox, the +largest Bitcoin exchange, has been unable to create any additional US +banking faculties. + In May 2013, the Department of Homeland Security issued a +seizure warrant to US payment processor Dwolla for the money in +Mt. Gox’s Dwolla account (Mutum Sigillum LLC, a US subsidiary +of Tokyo-based Mt. Gox). Mt. Gox is no longer processing any +funds through US banks. The company had failed to register in the +Regulatory History  +DOI: 10.1057/9781137382559.0008 +United States as a money transmitter and it appears that Mt. Gox +had allegedly been in violation of US banking regulations for about +18 months.5 + In July 2013, California-based Bank of the West began requesting +information regarding the application of money service business +regulations to the precious metals business of Amagi Metals +(Amagi, Inc.). While it was clear that Amagi Metals only accepted +Bitcoin as a method of payment, the bank closed their business +account citing that they believed it was a risk to do business +because of Bitcoin. Wells Fargo also rejected their business citing +that even “holding” virtual currency as a business prevents the +bank from offering them a new account.6 + In April 2013, New York-based Bitfloor closed down their operation +citing that the company’s US bank account had been involuntarily +closed.7 + Forbes Magazine reported in November of 2013 that BitInstant, a +New York Bitcoin trading company, had been denied accounts at +NY Chase, Wells Fargo, Citibank, and US Bank.8 + In July 2013, Jay Shore of Coinabul stated that both US Bank and +Chase had informed him they were closing the company’s bank +account.9 + Tradehill Inc., a California Bitcoin exchange agent, suspended +trading in August 2013 citing unspecified banking and regulatory +reasons from its bank Internet Archive Federal Credit Union +(IAFCU). Jered Kenna, CEO of Tradehill, says they have now been +turned down by over one hundred banks.10 + In late August of 2013, Jordan Modell, the CEO of the Internet +Archive Federal Credit Union, stated that certain operational and +regulatory issues had come to light and that the company would +be unable to offer any Bitcoin-denominated accounts until further +clarity was available.11 + Presently, the Tradehill website states that the company has +registered with FinCEN and is “actively engaging with banks and +regulators to continue development of future business products and +practices.”12 + In the second quarter of 2013, Bitbox, a Michigan Bitcoin exchange, +had its bank account at Comerica closed for no reason. Company +CEO Kinnard Hockenhull then moved to IAFCU only to encounter +the same problems months later. + The Digital Currency Challenge +DOI: 10.1057/9781137382559.0008 + Bitspend, a bitcoin-based company which allows visitors to buy +items on non-Bitcoin websites and pay in BTC, closed down +indefinitely. The former operator of Bitspend stated that Chase +bank decided that as a Bitcoin-based business it was too high risk +for the bank. Bitspend’s accounts were frozen and closed.13 +Today, US banks have no incentive to work with digital currency +exchange operations and traditional MSBs are having a difficult time +obtaining a US bank account. Based on the history of e-gold and other +exchange agent operations in the United States, it is likely that this trend +in the US market will continue with decentralized currency operations +related to Bitcoin. +In an interview with American Banker Magazine in May 2013, Jennifer +Shasky Calvery, the director of FinCEN, stated that she did not believe it +was MSB regulations that had “caused banks to de-risk themselves from +operating in the MSB arena.”14 However, she mentioned that regulatory +action and criminal enforcement against the biggest money launderer in +US history, a reference to the digital currency company Liberty Reserve, +could lead some banks to be overly aggressive in moving away from all +digital currency business. Over the long term, digital currency experts +believe that the MSB rule may have a negative effect on legitimate US +digital currency companies and even those foreign-located Bitcoin companies +seeking to do business in the United States.15 These actions are not +new. Since the 2005 e-gold raid, there has been a very well-recognized +pattern of isolating digital currency companies from access to US banks. +This strategy works well to cripple or close any digital currency business +operating from the United States. A similar situation occurred with digital +currency during 2005–2008. Citing the risks associated with “digital +currency,” the US banks were not handling accounts and doing business +for digital currency companies. This included merchant card processing. +In years past, when banks began turning down or closing digital currency +accounts, it was generally recognized as a sign that the US market +was fading. This same lack of access to US banks helped to close down +digital gold company Crowne Gold in July of 2008. +Today, the federal government and law enforcement agencies need to +take a more sensitive approach to the future of Bitcoin in America. US +regulators need to consider a “partnership” with decentralized currency +developers and new Bitcoin businesses. The reality of all global digital +currency, both past and future, is that users and merchants will either +Regulatory History  +DOI: 10.1057/9781137382559.0008 +thrive in a regulated legitimate US market or operate underground and +offshore. US banks can either fight the Bitcoin money service businesses, +with a tired e-gold strategy, or engage the industry in healthy dialogue +developing strategies that will cause the United States to become a +world leader in digital currency innovation. Long-term action should be +taken today in order to foster an environment where MSBs have access +to banking and financial services in the future. If US banks don’t start +cooperating with money transmitting Bitcoin-related businesses, all +those potential US Bitcoin transactions will find a home offshore. If the +business is pushed offshore, the United States will lose out on the creative +new products from a global market and also any second stage innovation. +Instead of becoming US partners in the fight to detect potential +Bitcoin money-laundering and terror financing, the government’s inaction +could result in much higher risks to consumers and an underground +marketplace that hinders law enforcement efforts to track illicit financial +transactions. Partnering with banks and new Bitcoin MSBs at this early +stage increases the probability of regulatory compliance and taxation +within US borders. +American merchants require US dollars. Online American merchants +accomplish everyday financial tasks through US banks. Whether the +operation is e-gold, Bitcoin, or any other digital currency, if everyday +access to US banks is blocked for a digital currency business, it is very +possible that a majority of US merchants and customers will avoid using +that digital currency product, since liquidity is one of the three driving +forces behind all successful digital currency systems. If the process of +exchanging digital currency into national currency is slowed or stopped, +US customers will be averse to using that financial product. +Additionally, the 2005 e-gold search warrant had permitted open +government access to all e-gold accounts. Prosecutors in the case caused +the Grand Jury to order complete dumps of the entire e-gold database on +at least three separate occasions during the investigation. This exposed +the financial records for tens of thousands of e-gold users never accused +of any crime and never involved in any criminal activity. This turned +out to be a particularly noteworthy act by government prosecutors. +Under the Right to Financial Privacy Act, 12 USC §§ 3401–342, customers +of digital currency companies should be afforded the same rights +as bank customers. The Right to Financial Privacy Act of 1978 protects +the confidentiality of personal financial records by creating a statutory +Fourth Amendment protection for bank records. The definition of + The Digital Currency Challenge +DOI: 10.1057/9781137382559.0008 +financial institution was expanded in July 2002 to include money service +businesses. Only specific e-gold accounts that had been identified as +involved in criminal activity should have been accessed. The RFPA states +that “no Government authority may have access to or obtain copies of, +or the information contained in the financial records of any customer +from a financial institution unless the financial records are reasonably +described.” +The statues requires that the requesting federal government agency must +give the customer advance notice of the requested disclosure from the +financial institution, thus giving the customer opportunity to challenge the +government’s access to the records before the disclosure takes place.16 +No charges were filed against e-gold in 2005 or 2006 and the digital currency +business continued to expand around the world. +In July of 2006, GoldAge, a very popular independent digital currency +exchange agent in New York, was closed and the owners arrested for +allegedly violating Article 13-B of New York State Banking Law. This digital +currency operation was one of the first to be charged with operating +a money transmitting business without a state license (New York). It is a +class “E” felony to engage in the business of transmitting money without +a license if one knowingly receives $250,000 or more for transmission +within a period of one year or less, $25,000 or more in a 30-day period +or less, and $10,000 or more in a single transaction. While the indictment +included only the illegal money transmitting activity from January +2006 through June 30, 2006, GoldAge had been one of the first exchange +agent operations in the United States and had originally opened, under +different owners, in 1999. In July 2006, the company’s bank accounts +were seized and never returned. The operators Arthur Budovsky and +Vladimir Kats lost an estimated several million in cash deposits and +volumes of personal client information and transaction details. The case +concluded with each party being found guilty in the State of New York +and sentenced to five years in prison. However, both sentences were +reduced to probation. +In a separate action by the Federal government, seven years later, in +May 2013, both Arthur Budovsky and Vladimir Kats were again arrested +along with others and charged by US Federal prosecutors under the USA +Patriot Act. After a lengthy investigation by authorities across 17 countries, +the government charged Budovsky, Kats, and others with money +laundering and operating an unlicensed financial transaction company +Regulatory History  +DOI: 10.1057/9781137382559.0008 +from Costa Rica. In what is alleged to be the largest money laundering +prosecution in US history, Liberty Reserve is said to have been used to +allegedly launder more than $6 billion in criminal proceeds during its +history. +For 16 months starting with the December 2005 e-gold raid through +April 2007, no criminal charges had been filed against e-gold or its +principles. During that time there were no civil actions or cases from +any other US regulatory agency. However, in April of 2007, US government +prosecutors presented evidence to a Grand Jury and indictments +were returned on the e-gold operation. On Friday, April 27, 2007, the +US attorney for the District of Columbia made public a four-count +indictment which charged e-gold Ltd., Gold & Silver Reserve Inc., and +owners Dr. Douglas L. Jackson, 50, of Satellite Beach; his brother Reid +A. Jackson, 44, of Melbourne; and Barry K. Downey, 47, of Woodbine, +Md., with four crimes: one count of conspiracy to launder monetary +instruments, one count of conspiracy to operate an unlicensed +money transmitting business, one count of operating an unlicensed +money transmitting—business under federal law—and one count +of money transmission without a license under DC law. Of the four +counts in the indictment, three related directly to operating without +the proper money transmitting license. At that same time, in separate +criminal actions, the government issued 24 seizure warrants on at least +58 large e-gold accounts. Alleging the e-gold contents included property +involved in money laundering and the operation of an unlicensed +money transmitting business, the government forced G&SR to seize +and liquidate the contents of the accounts. This included the accounts +of e-gold’s primary exchange agent OmniPay. US located independent +digital currency exchange agents and businesses transacting large +amounts of e-gold were the clear target of these seizures. Large US and +foreign exchange agents including The Bullion Exchange, AnyGoldNow, +IceGold, GitGold, The Denver Gold Exchange, GoldPouch Express, +and even the alternative payment system “1MDC,” which was backed +by e-gold, all lost substantial funds in the government action. The +gold bullion represented by all of the accounts was sold and the funds +were delivered to the government in the seizure. These independent +e-gold exchange agents had been buying and selling e-gold. At the +time, these companies were operating as independent exchange agents +for several digital currencies including e-gold. However, the seizure of +these exchange agent e-gold accounts occurred under the Racketeer + The Digital Currency Challenge +DOI: 10.1057/9781137382559.0008 +Influenced and Corrupt Organizations (RICO) statutes signaling the +government’s interest in pursuing third-party e-gold exchange agents. +The 1961 Racketeering Act, also known as the RICO Act, is a tool of law +enforcement which originally emerged to combat organized crime.17 +Due to the arrests and seizures, e-gold’s bullion reserves dropped from +112,188 ounces (3,491.0 kilograms) in April 2007 to 84,856 ounces (2,461.2 +kilograms) by June 2007. This was a drop of over 1,000 kilograms of gold +bullion. +While this coordinated legal action closed several of the industry’s +largest US exchange agents, including the primary dealer OmniPay, at +that time there were more than 120 active independent e-gold exchange +agents worldwide and the global e-gold business continued operating. +While exchange transactions decreased and merchant activity was +reduced, e-gold’s daily business did not stop and the operation remained +in existence. Seized funds from the 58 e-gold accounts and bank accounts +of G&SR were never returned. +The criminal case against e-gold was brought under Title 18 USC section +1960. The e-gold defendants made a determined argument that the +business should not be subject to current Treasury regulations, however, +the judge rejected the argument. In February 2008, e-gold had filed a +motion to dismiss the case on the grounds that the company’s business +did not fit the legal definition of a money transmitter. In May of 2008, +Judge Rosemary M. Collyer held that: + “money transmitting business” in governing criminal statute was +not restricted to business that handled cash; + defendants operated “money transmitting business” within +meaning of Money and Finance Code provision mandating +registration of such businesses; + criminal stature was not void for vagueness18; +From that date forward, the judge’s opinion made it very clear that anything +of value, not just cash or national currency, could be transmitted +online and was regulated under the existing law. +As part of an agreement, in July 2008, the company and its three directors +pleaded guilty. In November, Gold & Silver Reserve CEO Douglas +Jackson was sentenced to 300 hours of community service, a $200 fine, +and three years of supervision, including six months of electronically +monitored home detention. Reid Jackson, Douglas Jackson’s brother, +and e-Gold director Barry Downey were each sentenced to three years +Regulatory History  +DOI: 10.1057/9781137382559.0008 +of probation, 300 hours of community service, and ordered to pay a +$2,500 fine and a $100 assessment fee each.19 The plea agreement did not +close down the e-gold business. The business was permitted to continue +operating with the following significant restraints: + registration with FinCEN; + all required state money transmitter licensing; + creation and implementation of an anti-money laundering program +which includes rigorous customer verification; + suspicious activity reporting (SAR); + blocking of accounts for specially designated nationals (SDNs) and/ +or politically exposed people (PEP); + employee AML training; + independent audits; and + other safeguards to the system. +Unfortunately, as convicted felons, none of the former operators of +e-gold could ever be licensed, at any future time, for this type of work in +the US financial industry. The legal importance of this case should not +be understated. Judge Rosemary Collier’s 19-page Memorandum of Law +in Support of Defendants’ Motion to Dismiss Counts Two, Three and +Four of the Indictment changed the way digital currency was recognized +in America. For almost a decade e-gold had been operating unlicensed +using the justification the company never handled cash transactions and +was not required to be licensed. The court found this to be untrue and all +other digital currency businesses, from that date forward, were required +to be licensed at a federal and state level (several US states do not require +money transmitting licenses). This included digital currency providers, +operators, and all exchange agents. The e-gold case in 2008 was a landmark +case for digital currency. The ruling said that if the digital currency +is backed by gold, national currency, or by nothing and called a “decentralized +virtual currency,” that convertible digital value is recognized +by the US government, and those companies engaged in transmitting +value online are financial services which require proper licensing. This +is painfully obvious in the case Mt. Gox. Mark Karpeles, founder and +owner of Mt. Gox, could be facing charges as federal law enforcement +agents allege Mutum Sigillum, LLC engaged in a money transmitting +business although it was not registered with FinCEN and acted as an +unlicensed money service business in violation of 18 USC Section 1960. +The earlier case of GoldAge, in 2006, was another independent exchange + The Digital Currency Challenge +DOI: 10.1057/9781137382559.0008 +agent prosecuted for failing to obtain proper licensing in New York State. +The prosecution in 2008 of Michael Comer for operating Intgold digital +currency without a money transmitter license is another prime example. +There have been several prominent US cases in which digital currency +companies and their operators have been charged with operating an +unlicensed money transmitting business. Here is the short list of related +cases (partial list of charges per case for each individual): + Dr. Douglas Jackson, Reid Jackson, Barry Downey (e-gold) Count: +3 18:1960 and 2; Monetary Laundering; Prohibition of Unlicensed +Money Transmitting Business and Aiding and Abetting. + James Michael Fayed and Goldfinger Coin & Bullion, Inc. +(e-bullion), 2–08-cr-00224-PSG-1 USA v. Fayed et al, Count: 1 18 +USC § 1960 Operating an unlicensed money transmitting business +02/26/2008. + Michael Comer (Intgold) 3–08ncr-00085-N All Defendants USA +v. Comer 03/28/2008 Count: 1 18 USC § 1960 (a) and (b) (1) (B) +Operating an unlicensed money transmitting business. + Vladamir Kats (GoldAge), Arthur Budovsky (GoldAge) [State of +New York] Count: 2 18:371.F Conspiracy to operate an unlicensed +money transmitting business, Count: 3 18:1960.F Monetary +laundering (Operating an unlicensed money transmitting +business). + Vladamir Kats et al (Liberty Reserve S.A.), 1:13-cr-00368-DLC USA +v. Kats et al Date filed: 05/20/2013[Costa Rica], Count: 2 18:371.F +Conspiracy to operate an unlicensed money transmitting business, +Count: 3 18:1960.F Monetary Laundering (Operation of unlicensed +money transmitting business), With respect to Count 2, the Liberty +Reserve indictment specifically references the new July 2011 MSB +Rule and its application to foreign-based businesses. +Since 2008, there has been no question that US regulations require +digital currency businesses to be properly licensed. In fact, the original +e-gold conviction was obtained before the first Bitcoin ever circulated. +Despite the fact that both e-gold and e-bullion had, at separate times, +requested information from the government on whether or not the +companies were required to obtain the proper government licensing, +e-bullion in 2002 and e-gold in 2006, both companies were eventually +charged with crimes relating to operating without a money transmitter +license. +Regulatory History  +DOI: 10.1057/9781137382559.0008 +Notes + K. Griffith (kengriffith@gmail.com), e-bullion follow up, [email] message to +C. Mullan (carl@pdxcurrency.org), November 19, 2013. + Rediff.com, 2002. rediff.com: RBI Bans Gold Money as Payment Channel. +[online] Available at: http://www.rediff.com/money/2002/oct/22gold.htm +(accessed: December 13, 2013). + Asic.gov.au, 2004. Australian Securities and Investments Commission - 04–366 +ASIC Acts to Shut Down Electronic Currency Trading Websites. [online] Available +at: http://www.asic.gov.au/asic/asic.nsf/byheadline/04–366+ASIC+acts+to ++shut+down+electronic+currency+trading+websites (accessed: December +13, 2013). + FLORIDA TODAY, 2002. FLORIDA TODAY Breaking News Section. +[online] Available at: http://www.floridatoday.com/apps/pbcs.dll/ +article?AID=/20070428/BREAKINGNEWS/70428010/1086&nclick_check=1 +(accessed: December 13, 2013). + V. Buterin, 2013. MtGox’s Dwolla Account Seized for Unlicensed Money +Transmission. [online] Available at: http://bitcoinmagazine.com/4641/mtgoxsdwolla-account-seized/ +(accessed: November 18, 2013). + Reddit.com, 2013. Bank of the West Is Shutting Down Our Bank Account because +We Accept Bitcoins: Bitcoin. [online] Available at: http://www.reddit.com/r/ +Bitcoin/comments/1inixa/bank_of_the_west_is_shutting_down_our_bank/ +(accessed: December 13, 2013). + K. Hill, 2013. Bitcoin Companies and Entrepreneurs Can’t Get Bank Accounts. +[online] Available at: http://www.forbes.com/sites/kashmirhill/2013/11/15/ +bitcoin-companies-and-entrepreneurs-cant-get-bank-accounts (accessed: +December 13, 2013). + Ibid. + Ibid. + E. Spaven, 2013. Tradehill Suspends Trading Due to “Operational and Regulatory +Issues.” [online] Available at: http://www.coindesk.com/tradehill-haltstrading-due-to-iafcu-operational-and-regulatory-issues/ +(accessed: +December 13, 2013). + J. Modell, 2013. Rocky Road Is Still One of My Favorite Flavors « Internet Credit +Union. [online] Available at: https://internetcreditunion.org/uncategorized/ +rocky-road-is-still-one-of-my-favorite-flavors/ (accessed: December 13, +2013). + Finextra.com, 2013. Finextra: Tradehill Suspends Bitcoin Trading in Face of +Regulatory Heat. [online] Available at: http://www.finextra.com/News/ +FullStory.aspx?newsitemid=25165 (accessed: December 13, 2013). + Reddit.com, 2013. [Update/News] Why We Have Been Slow and Taking Longer +Than Usual to Process Orders. Hint, Banks Don’t Like Bitcoins: BitSpend. + The Digital Currency Challenge +DOI: 10.1057/9781137382559.0008 +[online] Available at: http://www.reddit.com/r/BitSpend/comments/1go95b/ +updatenews_why_we_have_been_slow_and_taking/ (accessed: December +13, 2013). + R. Blackwell, 2013. Fincen Chief Q&A: What We Expect from Digital Currency +Firms. [online] Available at: http://www.americanbanker.com/issues/178_104/ +fincen-chief-q-and-a-what-we-expect-from-digital-currency-firms- +1059485–1.html (accessed: December 16, 2013). + Ibid. + Epic.org, 2013. EPIC—The Right to Financial Privacy Act. [online] Available at: +http://epic.org/privacy/rfpa/ (accessed: December 13, 2013). + United States of America v. All Property in/underlying e-gold Account Number, 25 +Cases 1:07-cv-01322-RMC thru 1:07-cv-01345-RMC (2007). + Memorandum of Law in Support of Defendants’ Motion to Dismiss Counts +Two, Three and Four of the Indictment at 13–14, United States v. E-gold Ltd., +550 F. Supp. 82 (D.D.C. Feb. 11, 2008) (No. 07–109). + Department of Justice, 2008. Digital Currency Business E-Gold Pleads Guilty +to Money Laundering and Illegal Money Transmitting Charges. [press release] +Monday, July 21, 2008.