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U.S. Sanctions Update as of April 2024

U.S. Persons prohibited from transactions with anyone on the OFAC SDN List without a license, regardless of country. Includes entities owned in excess of 50-percent by one or more SDNs (33-percent for select Russian...more

U.S. Sanctions Update - April 2024

This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each...more

DOJ Charges Ten Individuals for Violating Venezuelan Sanctions

On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the...more

OFAC Rolls Back Venezuelan Sanctions Relief, Again Prohibiting Oil and Gas Transactions

On April 17, 2024, OFAC formally rolled back the sanctions relief it previously provided to the Venezuelan oil and gas industry.  While OFAC provided the initial relief believing that Venezuela would permit a fair and open...more

DOJ and CFTC Bring Charges Against Crypto Exchange KuCoin for AML and KYC Failures

On March 26, 2024, the U.S. Department of Justice (“DOJ”) unsealed an indictment against prominent cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang.  The DOJ charged the exchange and its founders...more

The SEC’s Recent Action Against Crypto Exchange ShapeShift Lacks Guidance and Draws Internal Criticism

On March 5, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced charges and a corresponding cease-and-desist order (the “Order”) with ShapeShift AG, a cryptocurrency exchange registered in Switzerland that...more

The UK Modern Slavery Act: Easy Wins and Practical Compliance (Part II of II)

In Part I, we discussed the basics behind the UK Modern Slavery Act of 2015.  To briefly reiterate, that Act requires any company doing business in the UK with an annual turnover of £36 million or more to publicize their...more

Compliance With the UK Modern Slavery Act: What It Means for Companies (Part I of II)

If you follow our blog, you’ll notice lately we’ve been writing frequently on topics related to human trafficking and modern slavery.  This is no accident, as new laws and regulations related to this growing area of...more

President Biden Issues Executive Order Concerning Bulk Data, With Parallels to Current Sanctions Regulations

On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States.  By issuing his Executive Order...more

TradeStation Settles Securities Violations Stemming From its Crypto Yield Product

On February 7, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced charges and a related cease-and-desist order (the “Order”) against TradeStation Crypto, Inc. (“TradeStation”) for failing to register the...more

Biden Administration Responds to Death of Alexey Navalny with Additional Sanctions Against Russia Federation

Following the death of opposition politician Alexey Navalny, the Biden Administration announced a large swath of new and additional sanctions on the Russian Federation.  The U.S. Department of Treasury’s Office of Foreign...more

OFAC Begins to Roll Back Venezuelan Sanctions Relief, Again Prohibiting Transactions with CVG Minerven

Easy come, easy go.  On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...more

Licencia 43a: reimposición de sanciones en Venezuela

El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionarle a Venezuela un alivio limitado a las sanciones...more

Quarterly Trade Compliance Update – January 2024

Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs....more

SEC Settlement with BarnBridge DAO and its Founders for Securities Violations Highlights Legal Risks for DAOs and DeFi

On December 23, 2023, BarnBridge DAO (“BarnBridge”) and its founders, Tayler Ward and Troy Murray, agreed to settle charges with the U.S. Securities and Exchange Commission (“SEC”).  BarnBridge violated Sections5(a) and 5(c)...more

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more

Lessons Learned from Binance’s Criminal Settlement (III of III)

Binance’s $4.3 billion fine is one of the largest penalties the DOJ has ever obtained from a corporate defendant.  Furthermore, its founder and CEO Changpeng Zhao (“CZ”) was also personally subject to a fine, amounting to...more

Binance Intentionally Avoided Compliance with U.S. Laws Under CEO Changpeng Zhao (II of III)

Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever.  A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very...more

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

SEC and DOJ Charge SafeMoon Cryptocurrency and its Executives For Multi-Million Dollar Fraud

On November 1, 2023, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) brought charges against cryptocurrency project SafeMoon LLC and its U.S. subsidiary SafeMoon US LLC, along with...more

A pesar del alivio en materia de sanciones comerciales por parte del gobierno de EE.UU al sector del petróleo y gas en Venezuela...

Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more

Despite OFAC Sanctions Relief, the Venezuelan Oil and Gas Industry Still Presents Risks

As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief.  Specifically, OFAC issued General License 44 (among...more

U.S. Sanctions Update as of October 2023

Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. About the document: ...more

La Oficina de Control de Activos Extranjeros (OFAC) otorgó alivios a las sanciones comerciales en Venezuela y autorizó ciertas...

El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more

OFAC Provides Venezuela with Sanctions Relief, Authorizes Certain Transactions in the Oil and Gas Industry

On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions.  The relief includes General Licenses...more

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