News & Analysis as of September 13, 2024

Economic Sanctions

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

The Shadow Financial System

White & Case LLP on 6/18/2024

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

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Morrison & Foerster LLP on 3/5/2024

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

Sheppard Mullin Richter & Hampton LLP on 11/27/2023

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

Executive Order Addresses Digital Assets; Banks and Restaurants Launch Crypto Initiatives; FinCEN Issues Alert; SEC, CFTC and DOJ...

BakerHostetler on 3/14/2022

This week, President Joe Biden signed “Executive Order on Ensuring Responsible Development of Digital Assets” (EO). According to a fact sheet published with the EO, the EO calls for measures to accomplish the following...more

Cryptocurrency and OFAC: Beware of the Sanctions Risks

Orrick - On the Chain on 1/24/2020

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

Crypto Never Sleeps: Vigilance Required in OFAC Sanctions Compliance Involving Virtual Currencies and Digital Assets

Dechert LLP on 12/17/2018

For years, regulators around the world have struggled with whether and how to police the offering and exchange of digital assets (including virtual currencies such as Bitcoin). In the United States, such efforts were stymied...more

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