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

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

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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

Lowenstein Sandler LLP

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

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Lowenstein Sandler’s Investment Management Group is pleased to provide you with the summaries and checklists described below. Summaries of recent legal developments with respect to: •SEC’s 2023 Examination Priorities- ...more

BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

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On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...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

American Conference Institute (ACI)

[Event] 16th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance - May 5th - 6th, Washington, DC

American Conference Institute (ACI) on

ACI’s Annual Flagship Conference on Economic Sanctions Enforcement and Compliance is widely regarded as the premier conference designed for those working in global sanctions compliance, internal audits and investigations,...more

K2 Integrity

Global Markets May Face Risk of Virtual Currency Abuse as Russian Actors Seek to Circumvent Sanctions

K2 Integrity on

The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...more

Orrick, Herrington & Sutcliffe LLP

Year-end Crypto Roundup — Five Key Concepts About the U.S. Government’s Recent Actions on Virtual Currency and Ransomware

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The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more

Akin Gump Strauss Hauer & Feld LLP

Treasury to Companies: Time to Take Ransomware Reporting Seriously

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On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more

Manatt, Phelps & Phillips, LLP

OFAC Speaks Again on Ransomware: Mature Cybersecurity Programs Are Important

Manatt, Phelps & Phillips, LLP on

Last year, as employees clicked away at home amid the COVID-19 pandemic lockdown, ransomware attacks surged, with hospitals and other health care providers the top target. This year will be worse—2021 has already seen more...more

The Volkov Law Group

Ransomware and OFAC Sanctions Compliance

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We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments.  The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering...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

Akin Gump Strauss Hauer & Feld LLP on

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

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on

Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

Ballard Spahr LLP

FinCEN Reports Spiraling SARs Relating to Ransomware

Ballard Spahr LLP on

On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more

Alston & Bird

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

Alston & Bird on

On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

Orrick, Herrington & Sutcliffe LLP on

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

Perkins Coie

OFAC Issues Second Ransomware Advisory and Designates Virtual Currency Exchange for Sanctions

Perkins Coie on

Agency’s Focus on Cryptocurrency and Blockchain Continues - On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more

Ballard Spahr LLP

OFAC Targets Virtual Currency Exchange for Allegedly Facilitating Ransomware Attack

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On September 21, 2021 OFAC issued its first sanctions designation against a virtual currency exchange by designating the virtual currency exchange, SUEX OTC, S.R.O. (SUEX) “for its part in facilitating financial transactions...more

Ballard Spahr LLP

OFAC Targets Virtual Currency Exchange For Ransomware Attack

Ballard Spahr LLP on

On September 21, 2021 OFAC issued its first sanctions designation against a virtual currency exchange by designating the virtual currency exchange, SUEX OTC, S.R.O. (SUEX) “for its part in facilitating financial transactions...more

Eversheds Sutherland (US) LLP

OFAC sanctions virtual currency exchange and updates ransomware advisory

Eversheds Sutherland (US) LLP on

On September 21, 2021, the US Department of the Treasury took actions in response to the increasing prevalence and severity of ransomware attacks in the United States and address the central role that virtual currency and...more

ArentFox Schiff

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

ArentFox Schiff on

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

Fenwick & West LLP

OFAC Helps Those Who Help Themselves: How a Ransomware Response Plan Can Help Avoid Sanctions Enforcement for Ransom Payments

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Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more

Sheppard Mullin Richter & Hampton LLP

First OFAC Sanctions Against a Cryptocurrency Exchange: Could the Designation of SUEX Signal an Enforcement Trend to Combat...

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On September 21, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According...more

Robinson+Cole Data Privacy + Security Insider

Update: Ransomware: To Pay or Not to Pay

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Three recent events are prompting me to update our previous blog post on the difficult decision of whether to pay or not to pay ransomware following an attack....more

Foodman CPAs & Advisors

Financial Institutions to Remain Vigilant of Ransomware Attacks as they are Facilitators of Ransomware Payments

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On October 1, 2020, the Financial Crimes Enforcement Network (FinCEN) issued an advisory to alert Financial Institutions (FI) relating to “predominant trends, typologies, and potential indicators of ransomware and associated...more

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