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Virtual Currency National Security

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 -
Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

A&O Shearman

Investigations update: Hong Kong authorities ramp up enforcement in virtual assets and other sectors

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Hong Kong has seen cryptocurrencies grow in popularity, highlighting the need for appropriate licensing regimes (implemented in the form of virtual asset service providers (VASPs)), bolstered by active enforcement actions. ...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - December 2023

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TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - September 2023

1. OFAC Imposes Sanctions on Russian Elites Who Were Board Members of Alpha Group- On Aug. 11, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Russian individuals, Petr...more

Foley Hoag LLP

Navigating the International Trade & National Security Landscape

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The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...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

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

Lowenstein Sandler LLP

Trade Matters - November 2021

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1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Publishes U.S. Sanctions Policy Review and Framework for Future Action

On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more

Jenner & Block

4 Key Questions Answered in OFAC’s Guidance for the Virtual Currency Industry

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On October 15, 2021, the US Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) issued guidance to help the virtual currency industry navigate and comply with OFAC sanctions. The guidance improves...more

WilmerHale

Treasury Releases Long-Awaited Sanctions Policy Review

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The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more

Bracewell LLP

OFAC Ransomware Update

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On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more

Morrison & Foerster LLP

DOJ Announces Renewed Focus on Export Control and Sanctions Enforcement

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In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more

ArentFox Schiff

OFAC Discourages Payment of Ransom, Suggests Reporting and Steps to Improve Cybersecurity Practices

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Agency Designates Virtual Currency Exchange and Leaves Insurance Questions Unanswered - On September 2, 2021, OFAC published an update to their October 2020 Ransomware Advisory. We reported on the original Ransomware...more

Foley & Lardner LLP

New FinCEN Anti-Money Laundering Priorities

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Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more

Latham & Watkins LLP

FinCEN Looks to Rein In Cryptocurrency Transactions

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A new proposal would subject financial institutions and exchanges to onerous recordkeeping and reporting requirements for certain digital currency transactions. In a surprise release in the waning days of the Trump...more

Rothwell, Figg, Ernst & Manbeck, P.C.

FinCEN’s Proposed Rulemaking for Cryptocurrency – The Balance of National Security vs. Privacy

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

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN and Federal Reserve Propose To Significantly Lower Threshold for International Funds Transfers Under Recordkeeping and...

On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more

Jones Day

FinCEN Issues Guidance on Ransomware Attacks

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The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more

King & Spalding

Virtual Currency as a Threat to National Security?

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In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Perkins Coie

Blockchain Week in Review - November 2019 #2

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U.S. Developments - Telegram Submits Answer to SEC Complaint Regarding TON Blockchain Network - On November 12, Telegram Group Inc. (Telegram) submitted its answer and affirmative defenses to a complaint filed against...more

Ballard Spahr LLP

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

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Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more

Robins Kaplan LLP

Financial Daily Dose 6.10.2019 | Top Story: U.S. Reverses Course on Tariffs Set to Hit Mexican Goods Today

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The White House announced on Friday that the US and Mexico reached a deal that it deemed sufficient to keep from levying the threatened 5% tariffs on Mexican goods that was set to take effect today. As details of that deal...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - July 2018 #4

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The Federal Energy Regulatory Commission (FERC) announced on July 19, 2018, that it is directing the North American Electric Reliability Corporation (NERC) “to develop and submit modifications to the NERC Reliability...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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The White House’s protectionist plan to impose roughly $60 billion in annual tariffs on Chinese imports went over like a lead balloon on Wall Street, sparking fears of a trade war, increased volatility, and unintended ripple...more

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