News & Analysis as of October 12, 2024

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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 -

Russia/Ukraine Sanctions Update - Month of September

Mayer Brown on 10/3/2024

I. US SANCTIONS - U.S. Department of the Treasury Acts Against Russian Virtual Currency Exchanges: On September 26, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network issued an...more

U.S. sanctions enforcement in the virtual currency space - USD 1 billion and counting...

A&O Shearman on 3/29/2024

Beginning in 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its enforcement activity on entities operating in the virtual currency space, illustrating a trend that...more

OFAC Year in Review 2023 – Part 1

Morrison & Foerster LLP on 3/4/2024

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

CryptoLink - December 2023 Updates

Akin Gump Strauss Hauer & Feld LLP on 1/19/2024

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

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

Lowenstein Sandler LLP on 12/11/2023

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

FinCEN Targets Convertible Virtual Currency Mixing to Combat Terrorist Financing and Other Illegal Transactions

Morrison & Foerster LLP on 10/27/2023

Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more

All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury...

Ballard Spahr LLP on 8/30/2023

Complex Civil and Criminal Cases Converge - On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more

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

Dechert LLP on 6/29/2023

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

The North Korean Crypto Threat

K2 Integrity on 10/17/2022

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

OFAC Sanctions Virtual Currency Mixer Tornado Cash

Dechert LLP on 9/16/2022

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on August 8, 2022, imposed sanctions against the popular decentralized virtual currency mixer Tornado Cash alleging that it has been used to launder...more

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

BakerHostetler on 8/15/2022

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

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

Sheppard Mullin Richter & Hampton LLP on 6/3/2022

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

Sanctions Against Russia: The Week in Review. - April 2022

K2 Integrity on 4/14/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

Sanctions Against Russia: The Week in Review - March 2022

K2 Integrity on 3/18/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more

Review of Sanctions and Export Control Developments in 2021 and What to Expect in 2022

Foley Hoag LLP - White Collar Law &... on 2/25/2022

This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more

OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Morrison & Foerster LLP on 2/9/2022

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

Treasury to Companies: Time to Take Ransomware Reporting Seriously

Akin Gump Strauss Hauer & Feld LLP on 12/14/2021

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

OFAC Sanctions Compliance Guidance for the Virtual Currency Industry

White & Case LLP on 11/22/2021

On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control ("OFAC") issued a brochure to promote sanctions compliance in the virtual currency industry (the "Guidance")1 and updated two related...more

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

Skadden, Arps, Slate, Meagher & Flom LLP on 11/11/2021

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more

US Department of the Treasury Announces Results of Sanctions Review

Kramer Levin Naftalis & Frankel LLP on 11/11/2021

On Oct. 18, 2021, the U.S. Department of the Treasury (the Treasury) announced the results of its review of U.S. economic and financial sanctions. During her confirmation hearing in January 2021, Janet L. Yellen, secretary of...more

Trade Matters - November 2021

Lowenstein Sandler LLP on 11/3/2021

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

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

Akin Gump Strauss Hauer & Feld LLP on 11/1/2021

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

DOJ and Treasury Take Crypto Enforcement to the Next Level

Latham & Watkins LLP on 10/29/2021

The DOJ’s National Cryptocurrency Enforcement Team and Treasury’s OFAC are setting their sights on cryptocurrency use in cybercrimes. The US Department of Justice (DOJ) is sharpening its focus on combatting...more

Sanctions 2.0: US Treasury Department announces results of sanctions policy review and OFAC releases compliance guidance for the...

Eversheds Sutherland (US) LLP on 10/29/2021

The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

Bracewell LLP on 10/27/2021

In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

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Virtual Currency › Office of Foreign Assets Control (OFAC) › U.S. Treasury

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