Liberty Reserve S.A

"Section 1010.660(a)(1) of the proposed rule would define Liberty Reserve to include all branches, offices, and subsidiaries of Liberty Reserve S.A. operating in Costa Rica or in any other jurisdiction."; "the Director of FinCEN found that Liberty Reserve S.A. (Liberty Reserve) is a financial institution operating outside of the United States that is of primary money laundering concern pursuant to 31 U.S.C. 5318A."

"Liberty Reserve is a web-based money transfer system, or “virtual currency.” It is a financial institution currently registered in Costa Rica and has been operating since 2001."; "Liberty Reserve was then based in Nevis and began as a private exchange system for import/export businesses."; "In March 2004, Liberty Reserve’s website indicated that it was operating out of Brooklyn, New York. In May 2006, Liberty Reserve was re-registered in Costa Rica."