The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule to counter money laundering and the financing of terrorism that would add significant compliance requirements for financial...more
The U.S. Department of the Treasury proposed regulations on June 21, 2024, that would prohibit certain outbound investments by U.S. persons in Chinese companies focused on semiconductors and microelectronics, quantum...more
The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Access Rule) regarding access to and use of beneficial ownership information (BOI) maintained by FinCEN....more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more
12/30/2021
/ Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Management ,
Virtual Currency
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more
10/13/2021
/ Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Mitigation ,
Sanctions ,
SDN List ,
Virtual Currency
The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more
8/20/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
FinTech ,
Popular ,
Suspicious Activity Reports (SARs) ,
Virtual Currency
On January 5, 2021, President Trump issued Executive Order 13971 (the “Executive Order”) that provides for prohibitions on U.S. persons engaging in transactions with persons that develop or control any of the following eight...more
1/11/2021
/ China ,
Data Collection ,
Executive Orders ,
Foreign Policy ,
Mobile Apps ,
National Security ,
Personal Data ,
Popular ,
Prohibited Transactions ,
Social Media ,
Software ,
Trump Administration
The Department of Justice (DOJ) announced last week and earlier this month civil forfeiture actions brought by the United States Attorney’s Office for the District of Columbia to seize stolen or laundered virtual currency...more
9/2/2020
/ Corruption ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Transactions ,
Forfeiture ,
Hackers ,
Money Laundering ,
Money Services Business ,
North Korea ,
Popular ,
Terrorist Financing Regulations ,
Virtual Currency ,
White Collar Crimes
A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more
1/24/2020
/ Anti-Money Laundering ,
Bitcoin Mining ,
BSA/AML ,
CFTC ,
Corruption ,
Cryptocurrency ,
Currency Exchange ,
Digital Currency ,
Economic Sanctions ,
Financial Transactions ,
FinCEN ,
Geo-Blocking ,
Jurisdiction ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Oversight ,
Risk Management ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Strict Compliance ,
Strict Liability ,
Virtual Currency
The Committee on Foreign Investment in the United States ("CFIUS") issued final regulations on January 13, 2020 to comprehensively implement the Foreign Investment Risk Review Modernization Act of 2018 ("FIRRMA") (the...more
1/21/2020
/ CFIUS ,
Change of Control ,
Corporate Counsel ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Filing Requirements ,
Final Rules ,
FIRRMA ,
Foreign Investment ,
Investment ,
Investment Funds ,
Jurisdiction ,
National Security ,
New Regulations ,
Personal Data ,
Popular ,
Principal Place of Business ,
Real Estate Investments ,
Real Estate Transactions ,
Regulatory Requirements ,
Sensitive Personal Information
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
1/2/2020
/ Aircraft ,
Aircraft Equipment ,
Aircraft Sales ,
CAATSA ,
Criminal Investigations ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Department of Defense (DOD) ,
Drug & Alcohol Abuse ,
Drug Trafficking ,
Economic Sanctions ,
Energy Policy ,
Energy Projects ,
Entity List ,
Export Administration Regulations (EAR) ,
Exports ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Persons ,
Foreign Relations ,
Germany ,
Huawei ,
Iran ,
Iran Sanctions ,
National Security ,
Natural Gas ,
NDAA ,
North Korea ,
Oil & Gas ,
Opioid ,
Pain Management ,
Patriot Act ,
Pharmaceutical Industry ,
Pipelines ,
Popular ,
Procurement Guidelines ,
Risk Management ,
Russia ,
Strict Compliance ,
Supply Chain ,
Syria ,
Telecommunications ,
Trump Administration ,
Turkey ,
U.S. Commerce Department ,
United Nations