Numerous jurisdictions across the globe are developing their own cryptoasset regulatory frameworks—the UK is no exception. Cryptoasset businesses overseas looking to enter the UK market, or to offer services to customers in...more
Key takeaways FinCEN and Treasury announce that there will be no enforcement for failure to file beneficial ownership information reports with FinCEN by the March 21 deadline. Treasury announced intention to narrow the scope...more
As described in our previous client alert, on January 23, 2025, the Supreme Court of the United States stayed the nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas...more
Key takeaways TLDR: No mandatory BOI/CTA filing yet, but stay tuned pending resolution of a second case and subsequent FinCEN guidance. On January 23, 2025, the Supreme Court of the United States stayed the nationwide...more
What is happening Many of the largest blockchain networks today are subject to a proof-of-stake (PoS) consensus mechanism, such as Ethereum, Solana, and Polygon, which are reliant on users participating in the activity of...more
On October 19, 2021, FinCEN, the U.S. Government’s lead AML regulator, exercised its regulatory relief authority to allow casinos and card clubs to employ “non-documentary means” to verify patrons’ identity. The original...more
The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more
A significant focus on tax compliance and follow-up enforcement actions may be on the horizon. We previously reported that the Internal Revenue Service (IRS) Cyber Crimes Unit had signaled its determination to increase...more
Key developments of interest over the last month include: • United Kingdom: The Payment Systems Regulator (PSR) has published two calls for views, one of which focuses on authorised push payment (APP) scams and the other on...more
Ransomware victims face a nearly impossible decision: pay criminals holding their business hostage or refuse and face possible crippling consequences. This decision requires careful analysis of a number of considerations, and...more
2/25/2021
/ Cyber Attacks ,
Cyber Crimes ,
Cybersecurity ,
Data Breach ,
Hackers ,
Incident Response Plans ,
Information Technology ,
New Guidance ,
NYDFS ,
Personally Identifiable Information ,
Popular ,
Ransomware
The U.S. is one of the easiest jurisdictions in the world in which to do business1 . 1 Regulatory barriers are generally low, establishing a branch or business entity is quick and easy, labor and employment laws are much...more
On Tuesday, November 3, 2020, Americans chose the presidency and the makeup of the United States Congress. With the U.S. election now decided, with the exception of the Georgia Senate races, we are delighted to share with you...more
12/29/2020
/ 5G Network ,
Antitrust Provisions ,
Biden Administration ,
CFIUS ,
Coronavirus/COVID-19 ,
Foreign Investment ,
Healthcare Reform ,
Infectious Diseases ,
Infrastructure ,
Presidential Elections ,
Public Transportation ,
Regulatory Reform ,
Tax Reform
Brace for increased regulation of the financial services industry and federal enforcement under the Biden Administration with a focus on consumer protection and debt collection, discrimination in the housing and consumer...more
The Cuban Assets Control Regulations have been amended to prohibit U.S. persons from lodging at certain properties in Cuba, incorporate restrictions on imports of Cuban alcohol and tobacco, and revoke general licenses...more
In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more
10/6/2020
/ AML/CFT ,
BSA/AML ,
Cyber Crimes ,
Cyber Insurance ,
Cybersecurity ,
Economic Sanctions ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Money Services Business ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Privacy Concerns ,
Ransomware ,
Suspicious Activity Reports (SARs)
The U.S. Department of Justice (DoJ) has announced that the co-founder of a cryptocurrency company who misled victims into investing $25 million in a fraudulent scheme has pled guilty for his role in the scheme and faces up...more
The Commodity Futures Trading Commission (CFTC) has approved final interpretative guidance on retail commodity transactions involving certain digital assets, clarifying the agency's views in respect of the "actual delivery"...more
The U.S. Securities and Exchange Commission (SEC) has obtained an asset freeze and other emergency relief to stop an alleged securities fraud by former Washington state senator David Schmidt and two others, who dishonestly...more
As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List.
Summary -
Companies that use Iran Air as transport, particularly companies engaging in...more
3/17/2020
/ Airlines ,
Aviation Industry ,
Bureau of Industry and Security (BIS) ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions
On 27 February 2020, the Office of Foreign Assets Controls (OFAC) issued General License (GL) 8 authorizing certain humanitarian trade transactions involving the Central Bank of Iran (CBI) that are otherwise prohibited under...more
3/6/2020
/ Banks ,
Commodities ,
Economic Sanctions ,
Food Supply ,
Foreign Relations ,
General Licenses ,
Global Terrorism Sanctions Regulations (GTSR) ,
Humanitarian Assistance ,
Iran ,
Iran Sanctions ,
ITSR ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Requirements ,
Reporting Requirements ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Switzerland ,
Trade Agreements
The G20 has urged countries to adopt the Financial Action Task Force (FATF) standards on virtual assets and virtual asset service providers, which were adopted in June last year.
...more
2/28/2020
/ Bitcoin ,
Blockchain ,
BSA/AML ,
Committee on Payments and Market Infrastructure (CPMI) ,
Cross-Border Transactions ,
Cryptoassets ,
Cryptocurrency ,
Digital Currency ,
Digital Service Providers ,
FATF ,
Financial Instruments ,
Financial Services Industry ,
G20 ,
Popular ,
Virtual Currency
A Ukrainian man living in the U.S. is facing up to 20 years in prison after being convicted of 18 federal felonies to defraud his former employer Microsoft out of more than $10 million in digital value.
...more
2/28/2020
/ Bitcoin ,
Blockchain ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Digital Currency ,
Former Employee ,
Fraud ,
Gift-Cards ,
Identity Theft ,
Internet Retailers ,
Microsoft ,
Mobile Devices ,
Money Laundering ,
Online Platforms ,
Tax Fraud ,
Tax Returns ,
Unauthorized Access ,
White Collar Crimes ,
Wire Fraud
The U.S. Commodity Futures Trading Commission (CFTC) has charged a man from Colorado with fraud and failing to register with it in respect of a scheme that involved Ponzi-type payments....more
2/21/2020
/ Bitcoin ,
Blockchain ,
Civil Monetary Penalty ,
Commodity Pool ,
Cryptocurrency ,
Digital Assets ,
Disgorgement ,
Enforcement Actions ,
Foreign Currency ,
Forex ,
Illegal Trading ,
Investment ,
Investment Fraud ,
Misappropriation ,
Permanent Injunctions ,
Ponzi Scheme ,
Restitution ,
Solicitation ,
White Collar Crimes
The U.S. Department of Justice (DoJ) has indicted a man from Ohio for running Helix, a darknet-based cryptocurrency laundering service that is alleged to have laundered bitcoins worth $300 million....more
2/18/2020
/ Belize ,
Bitcoin ,
Blockchain ,
Criminal Conspiracy ,
Criminal Investigations ,
Criminal Prosecution ,
Cryptocurrency ,
Darknet ,
Department of Justice (DOJ) ,
Digital Currency ,
Indictments ,
Money Laundering ,
Money Services Business ,
Money Transmitter ,
Popular ,
Search Warrant ,
Virtual Currency
IOSCO has published its final report on the issues, risks and regulatory considerations associated with CTPs, which includes key considerations to help regulatory authorities address those issues. ...more
2/14/2020
/ Conflicts of Interest ,
Cryptoassets ,
Cryptocurrency ,
Initial Coin Offering (ICOs) ,
Investment Funds ,
Investment Opportunities ,
IOSCO ,
Regulatory Standards ,
Risk Management ,
Secondary Markets ,
Securities Regulation ,
Token Sales ,
Trading Platforms ,
Transparency