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Virtual Currency › Sanctions

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 -
A&O Shearman

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

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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

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

Pillsbury Winthrop Shaw Pittman LLP

OFAC Issues New Sanctions Targeting Hamas’s Financing Networks

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Following the October 7 attack on Israel by Hamas, the Treasury Department’s Office of Foreign Assets Control (OFAC) has undertaken several initial sanctions steps to counter terrorist financing and call attention to...more

Sheppard Mullin Richter & Hampton LLP

OFAC Continues Focus on Virtual Currency Industry with Announced Settlement with Payward, Inc.

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Yesterday, on November 28, 2022, the Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement agreement with Payward, Inc. (Kraken), an online virtual currency exchange, in connection with 826 apparent...more

Dechert LLP

OFAC Sanctions Virtual Currency Mixer Tornado Cash

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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

Perkins Coie

OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more

Morrison & Foerster LLP

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

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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

A&O Shearman

Sanctions Roundup: Fourth Quarter 2021

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Closing the year with a renewed focus on the People’s Republic of China, the Biden Administration imposed new export restrictions on US-origin technology to Chinese tech firms to hinder the PRC’s military and security...more

Wilson Sonsini Goodrich & Rosati

2021 U.S. Sanctions Year in Review

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In January 2021, President Biden was sworn into office and for the first time in a decade, Democrats assumed control of both chambers of Congress. Notwithstanding these changes, the U.S. government has continued to rely on...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

White & Case LLP

OFAC Sanctions Compliance Guidance for the Virtual Currency Industry

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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

McDermott Will & Emery

OFAC Reaffirms Focus on Virtual Currency with Sanctions Law Guidance

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On October 15, 2021, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) announced updated guidance for virtual currency companies in meeting their obligations under US sanctions laws. On the same day,...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

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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

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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

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...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

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

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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

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

K2 Integrity

Virtual Assets and Sanctions: What Businesses Need to Know

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As virtual assets explode in value, use, and popularity, governments around the world are taking notice, increasing sanctions-related scrutiny of companies that provide related services and focusing regulatory and enforcement...more

Pillsbury - Global Trade & Sanctions Law

BitPay Inc. Enforcement Action Highlights Sanctions Compliance Risks for Virtual Currency Service Providers

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On February 18, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) entered into a settlement of $507,375 with BitPay, Inc. (BitPay) for violations of multiple U.S. sanctions programs. According to...more

Ballard Spahr LLP

Two Chinese Nationals Charged with Money Laundering Over $100 Million in Cryptocurrency for North Korea

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Case Sheds Light on Latest Methods to Evade Detection: “Peeling” Chains - On March 2, the U.S. government sanctioned and indicted two Chinese nationals for helping North Korea launder nearly $100 million in stolen...more

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