On May 5, Ripple Labs Inc. (“Ripple”), along with its wholly owned subsidiary XRP II, LLC (“XRP II”), reached a non-prosecution agreement with the U.S. Attorney’s Office in the Northern District of California to resolve a criminal investigation.  Ripple is the developer and seller of XRP, the second most used form of digital currency.  The U.S. Attorney’s Office investigated allegations that Ripple and XRP II failed to comply with laws regulating the exchange of virtual currency.  Money services businesses are required to register with the Financial Crimes Enforcement Network (“FinCEN”), but Ripple began selling currency without doing so.  The investigation also addressed allegations that the companies did not have an appropriate anti-money laundering program in place.  Remedial measures under the settlement agreement include the migration of Ripple’s currency exchange business into a separate entity registered with FinCEN, ongoing cooperation with other investigations, enhancements to the company’s anti-money laundering controls and training programs, forfeiture and penalties totaling $700,000, and submission to external audits through 2020.  Ripple also resolved a parallel FinCEN enforcement action.  DOJ Press Release