All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more
Last week, the United States Attorney’s Office for the Southern District of New York unsealed an indictment against global cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang, for allegedly conspiring...more
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
Hong Kong regulators recently brought criminal enforcement actions against virtual asset trading platform JPEX and individuals associated with the platform. This case has become the first opportunity for local authorities to...more
Crypto Asset Company Settles Sanctions Violations for $7.5 million- On May 1, the U.S. Department of Foreign Assets Control (OFAC) announced a $7.5 million settlement with crypto asset company Poloniex LLC for 65,942 apparent...more
Companies are increasingly choosing not to pay ransom for ransomware and extortionware due to the growing associated risks. In fact, a recent report by crypto-crime analyst firm Chainalysis found that payments to threat...more
Despite the ongoing “Crypto Winter,” the use of NFTs continues to rise. NFTs are associated most often with pictures, videos, and music, but developers have been finding many new and useful applications for them. As the...more
On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more
The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters....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
Key developments of interest over the last month include: United Kingdom: HM Treasury responds to Payments Landscape Review call for evidence Hong Kong: HKMA publishes white paper exploring the idea of a CBDC Italy: Bank of...more
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
I recently came across a paper prepared by students from Columbia’s School of International and Public Affairs that delves into the benefits that cryptocurrency and the blockchain can provide to the world’s unbanked....more
On August 10, 2021, the Commodity Futures Trading Commission (CFTC) and the Financial Crimes Enforcement Network (FinCEN) announced a near-record settlement of $100 million with BitMEX, a cryptocurrency derivatives exchange....more
As cryptocurrency’s market cap surpasses the $2.5 trillion mark and continues to climb, global regulators have turned their attention to understanding and addressing the risks surrounding digital assets. In recent years,...more
Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more
On Friday March 12, Bloomberg News reported that the Commodity Futures Trading Commission (“CFTC”) has opened an inquiry into Binance Holdings Ltd. (“Binance”) to investigate allegations that the exchange allowed US citizens...more
Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more
U.S. Developments - Regulatory Developments - CFTC Announces Two Events Designed to Encourage FinTech Innovation - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) announced two events designed to...more
The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more
This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more