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Don’t Get Caught Up in the Mix: OFAC Sanctions Another Crypto Mixer for Potential Violations of Sanctions Regulations and FinCEN...

U.S. government agencies continue to take action against cryptocurrency mixing services that enable cybercriminals to obfuscate the trail of stolen proceeds on public blockchains stemming from illicit cyber activity. On...more

Q&A: The Bottom Line of Russian Sanctions’ Impact on AML for Private Funds

Earlier this spring, following the Russian invasion of Ukraine, the Biden administration issued a series of executive orders imposing strong sanctions against Russia. Over the last few months, those sanctions have continued...more

Economic Sanctions and Asset Seizures: An Important Focus for the Biden Administration

Sanctions continue to be a dynamic area of regulation and enforcement. In its first year, the Biden Administration has already undertaken a number of different sanctions initiatives. The three examples below highlight the...more

Moving SWIFTly: What You Need to Know Now about the Rapidly Evolving Sanctions against Russia

In response to Russia’s invasion of Ukraine, President Biden announced sanctions against Russia.  Following an executive order issued on February 21, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

No Hearing? No Money: Second Circuit Holds the Government May Not Keep Illegally Seized Rent

The Second Circuit has recently held that the Government must account for rental income it denied a property owner during a period of illegal seizure even though the Government was able to establish probable cause at a...more

Chinese Military Companies Trading Ban: Overview of OFAC’s Ongoing Guidance

On November 12, 2020, the Trump Administration issued an Executive Order prohibiting U.S. persons from trading securities and related derivatives in “Communist Chinese Military Companies” (CCMCs), effective 60 days later on...more

Regulatory Crackdown on Ransomware

Ransomware is a Serious and Growing Problem - In recent years, Ransomware has evolved from merely encrypting files/disabling networks in solicitation of ransom, to sophisticated attacks that often involve actual data...more

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