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Virtual Currency › Cryptocurrency › Office of Foreign Assets Control (OFAC)

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... more +
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 -
White & Case LLP

The Shadow Financial System

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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

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - December 2023 Updates

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On the one hand, the year ended where it began. The legislation on stabelecoins and market structure that would provide a regulatory framework for digital assets has still not been enacted into law. And Securities and...more

Sheppard Mullin Richter & Hampton LLP

Sanctions Enforcement in the Cryptocurrency Industry Continues to be a Focus

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On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more

Sheppard Mullin Richter & Hampton LLP

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

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The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

Sheppard Mullin Richter & Hampton LLP

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

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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

BakerHostetler

Crypto Firms Launch New Initiatives; Whitepapers Address DeFi, Crypto Risks, CBDCs; OFAC Adds Crypto Addresses to SDN List...

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Crypto Firms Continue to Launch New Initiatives Across Markets - In a recent press release, digital asset infrastructure firm Fireblocks announced its acquisition of BlockFold, “a smart contract development and...more

Orrick - On the Chain

6 Questions Blockchain Founders Should Ask When Launching a Product or Token

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As any founder knows, operating in the blockchain space requires navigating a myriad of regulatory regimes. While every product and token are different, below are 6 key questions that any founder should ask themselves as they...more

Dechert LLP

When You Got It, Flaunt It: Enforcement Authorities Expect Companies, Including Banks and Cryptocurrency Exchanges, That Collect...

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently announced two settlements that underscore OFAC’s continued emphasis on companies developing and implementing effective, risk-based...more

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions actors facilitating DPRK virtual currency laundering

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On April 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Orders 13722 and 13382, against three individuals for providing material support to the Democratic...more

Troutman Pepper

OFAC Settles With Kraken for $362,158: Maximum Penalty Avoided

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On November 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement with Payward, Inc. d/b/a Kraken. The Delaware-incorporated virtual currency exchange allegedly...more

Ballard Spahr LLP

Kraken Settlement Demonstrates Importance of Sanctions Monitoring for Transactions — Not Just When Onboarding Customers

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The Office of Foreign Assets Control (“OFAC”) announced (here and here) yesterday that virtual currency exchange Payward, Inc. – better known as Kraken – has agreed to pay $362,158.70 in order to settle its potential civil...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

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On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Holland & Knight LLP

Crypto Company Comes Under OFAC Scrutiny

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 11, 2022, announced a more than $24.28 million settlement with Bittrex Inc. (Bittrex), a Bellevue, Washington-based company that offers...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

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The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

K2 Integrity

The North Korean Crypto Threat

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Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Ballard Spahr LLP

Civil Complaint Challenges OFAC’s Tornado Cash Sanctions

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Last month, the Office of Foreign Assets Control (“OFAC”) sanctioned Tornado Cash, a virtual currency “mixer” operating on the Ethereum blockchain which allegedly has been used to launder the virtual currency equivalent of...more

Kelley Drye & Warren LLP

The Crypto Weekly - September 2022 Issue #2

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The below articles and industry developments have been identified by Kelley Drye and Warren’s Blockchain and Cryptocurrency practice group as relevant during the week of September 7 – September 13. We hope you find this...more

Paul Hastings LLP

Top PHive Crypto Enforcement Notes: September Edition

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Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts

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A flurry of legal and enforcement activity has arisen over the last two weeks across a wide range of areas in the Web3 space, including actions by the Securities and Exchange Commission, the Office of Foreign Assets Control,...more

Husch Blackwell LLP

OFAC's Crackdown on Tornado Cash Protocol Raises Specter of Future Liability Concerns

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The Office of Foreign Assets Control (OFAC) recently made the unprecedented move of sanctioning a smart contract — a decentralized digital currency mixer called “Tornado Cash” — along with certain cryptocurrency addresses...more

BakerHostetler

Crypto Products Launch, Gain Approvals; OFAC Sanctions Crypto Mixer; SEC Publishes ICO Consent Order; Report Cites Criminal Use of...

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NY DFS Approves Crypto Platform, Prepaid Crypto Card to Launch in Argentina - According to a press release this week, the New York State Department of Financial Services (NY DFS) has authorized two subsidiaries of Zero...more

Orrick, Herrington & Sutcliffe LLP

5 Things to Know About OFAC Sanctioning Crypto Mixer Tornado Cash

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The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned the popular decentralized virtual currency mixer Tornado Cash on August 8, 2022, continuing the U.S. government’s efforts to target...more

Sheppard Mullin Richter & Hampton LLP

The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

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On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more

Dechert LLP

“WRONG”: U.S. Court Affirms Sanctions Risks in Virtual Currency Transactions

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Key Takeaways - A judge has issued an opinion in a first-of-its-kind criminal sanctions case involving the use of virtual currency to evade U.S. economic sanctions. The opinion reinforces the Treasury Department’s position...more

Mintz

DOJ issues charges in first criminal cryptocurrency sanctions case

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Last Friday, a federal Magistrate Judge in Washington, D.C. wrote an opinion, in a still sealed case, explaining why he approved a DOJ criminal complaint against an American citizen accused of transmitting more than $10...more

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