News & Analysis as of

Office of Foreign Assets Control (OFAC) Money Transmitter

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - December 2023 Updates

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

The Volkov Law Group

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

The Volkov Law Group on

On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

BakerHostetler

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

BakerHostetler on

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

Venable LLP

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

Venable LLP on

​​​​​​​The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

BakerHostetler

Applying the Bank Secrecy Act, FinCEN Regulations, and Sanctions to the Nascent NFT Market

BakerHostetler on

Non-fungible tokens (NFTs) often involve two areas with known money laundering and terrorist financing risks: cryptocurrencies and high-value assets, like art. As detailed below, the U.S. Treasury Department’s Financial...more

The Volkov Law Group

Payoneer Pays $1.4 Million to Resolve OFAC Sanctions Violations

The Volkov Law Group on

Payoneer, Inc., an online money transmitter and prepaid access company, agreed to pay $1.4 million to OFAC to settle violations of multiple sanctions programs.  ...more

McGlinchey Stafford

Scared Of Your Clients’ Involvement With Cryptocurrency?

McGlinchey Stafford on

Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Are Nonfungible Tokens Subject to US Anti-Money Laundering Requirements?

Rapidly growing interest in nonfungible tokens (NFTs) has been fueled by recent headlines of multimillion-dollar transactions, such as the $69 million sale of an NFT by digital artist Beeple — the third-highest price ever...more

ArentFox Schiff

Non-Fungible Tokens: The Blockchain Technology Raising Legal Issues

ArentFox Schiff on

Non-fungible tokens or NFTs are digital assets that run on blockchain. The value of NFTs largely stems from the idea of scarcity. Collectors of NFTs can own unique digital assets like art, sports highlights, or songs which...more

Sheppard Mullin Richter & Hampton LLP

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Jones Day

NYDFS Rejects Cryptocurrency Exchange License Applications, Citing Compliance Program Flaws

Jones Day on

The Situation: For the first time, the New York State Department of Financial Services ("NYDFS") publicly announced that it had denied a cryptocurrency exchange's applications for virtual currency and money transmission...more

Ward and Smith, P.A.

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on

Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more

Ballard Spahr LLP

NY DFS Finalizes Rigorous AML/BSA Regulation

Ballard Spahr LLP on

The New York Department of Financial Services (DFS) has finalized a new regulation setting forth rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and...more

Ballard Spahr LLP

NYDFS Finalizes AML/BSA Regulation

Ballard Spahr LLP on

The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more

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