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

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

Myanmar Sanctions – A Last Resort Against a Non-Cooperating Country

On October 21, 2022, the Financial Action Task Force (FATF) officially moved Myanmar onto the agency’s blacklist, where it joins Iran and North Korea, the only other two listed countries. It is likely that the United States...more

Crypto and Russia Sanctions: A Primer and Survival Guide For Crypto Companies

The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money...more

Treasury’s Study Discusses Financial Crimes and NFTs

On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade. Among other considerations, the report discussed the risks of financial...more

Clearing the Air: FinCEN Guidance May Help Banks Find Their Way in the Field of Hemp Financing

On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published updated guidance intended to “enhance the availability of financial services” for the hemp industry (the Guidance). Even though the Agriculture...more

BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of...more

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