News & Analysis as of

Office of Foreign Assets Control (OFAC) Cryptocurrency

Venable LLP

A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash

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On March 21, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) officially lifted sanctions on Tornado Cash, the decentralized cryptocurrency mixer it had blacklisted in August 2022....more

Troutman Pepper Locke

Navigating 2025: Trends in OFAC and DOJ Enforcement for Digital Assets — The Crypto Exchange Podcast

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In this episode of Crypto Exchange, host Ethan Ostroff is joined by his colleagues Pete Jeydel and Peter Leary to discuss trends and lessons learned from recent civil enforcement actions by the Treasury Department's Office of...more

BakerHostetler

Weekly Blockchain Blog - April 2025

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U.S. Financial Services Firms Announce Digital Asset Initiatives - A major U.S. financial services company and operator of global financial exchanges and clearinghouses recently announced an agreement with the issuer of the...more

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

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Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - March 20, 2025

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Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more

Troutman Pepper Locke

Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast

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In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory discuss the latest FinCEN and OFAC guidance on virtual currency transactions, specifically tailored for companies in the payments industry. They...more

BakerHostetler

Weekly Blockchain Blog - March 2025 #2

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Executive Order Establishes Strategic Bitcoin Reserve, Digital Asset Stockpile - On March 6, President Trump issued an executive order (EO), Establishment of the Strategic Bitcoin Reserve and United States Digital Asset...more

Faegre Drinker Biddle & Reath LLP

The Wallet Inspectors: The DPRK’s Sophisticated Campaign to Steal Cryptocurrency and How to Protect Yourself

On February 21, 2025, Bybit, one of the world’s largest cryptocurrency exchanges, suffered a cyberattack resulting in the theft of approximately $1.5 billion in Ethereum tokens.  This attack marked a new pinnacle in the...more

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 35

Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds....more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

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We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

Paul Hastings LLP

Crypto Executive Order: A New Era for Digital Assets

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President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more

Fenwick & West LLP

Crypto Week in Review - January 2025

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The Trump administration’s first week back in office was marked by a flurry of crypto-related activity among regulators, lawmakers, and the market itself....more

Troutman Pepper Locke

Unpacking the Fifth Circuit's Landmark Tornado Cash Decision — The Crypto Exchange Podcast

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In this episode of the Crypto Exchange, Ethan Ostroff is joined by colleagues Pete Jeydel and Matt Orso to discuss a recent landmark decision from the Fifth Circuit regarding Tornado Cash. The court ruled that the Office of...more

BakerHostetler

Weekly Blockchain Blog - December 2024 #3

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Digital Asset Companies Achieve Licenses, Launch Stablecoin Products - According to a recent press release, Anchorage Digital, a digital asset platform and infrastructure provider, announced that the New York State...more

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

BCLP on

Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - November 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Bracewell LLP

An "Immutable" Force Meets an Immovable Object: OFAC's Crypto Loss at the Fifth Circuit

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On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more

Hogan Lovells

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

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The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

Latham & Watkins LLP

Fifth Circuit Overturns OFAC Sanctions Against Crypto Mixer Tornado Cash

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The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes....more

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

A&O Shearman on

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...more

Mayer Brown

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

Mayer Brown on

On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

Orrick, Herrington & Sutcliffe LLP

5th Circuit reverses and remands cryptocurrency software case stating OFAC exceeded its authority

On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more

Constangy, Brooks, Smith & Prophete, LLP

You’ve been hit with ransomware. Think twice before you pay.

You've been hit by a ransomware attack, and a cybercriminal group is demanding a cryptocurrency payment in exchange for your data's safe return. Should you pay? Deciding whether to pay a ransom is an internal business...more

Bracewell LLP

Enforcement Trends 2025: Magic 8 Ball Says "Try Again Later"

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As the world prepares for the change of administration in January, current government officials and industry experts convened at the New York Forum on Economic Sanctions to reflect on enforcement trends in 2024, and to...more

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