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Virtual Currency › Cybersecurity › Enforcement Actions

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

A&O Shearman

Investigations update: Hong Kong authorities ramp up enforcement in virtual assets and other sectors

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Hong Kong has seen cryptocurrencies grow in popularity, highlighting the need for appropriate licensing regimes (implemented in the form of virtual asset service providers (VASPs)), bolstered by active enforcement actions. ...more

Orrick, Herrington & Sutcliffe LLP

Top 5 Takeaways from NYDFS $1.2 Million Fine in Cybersecurity Case

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On May 1, the New York Department of Financial Services (“NYDFS” or “Department”) and a trading platform entered into a consent order to resolve deficiencies identified during examinations conducted in 2018 and 2020. The...more

Orrick, Herrington & Sutcliffe LLP

Crypto trading platform reaches $1.2 million settlement to resolve alleged compliance failures

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On May 1, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of the state’s cybersecurity regulation (23 NYCRR Part 500)...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

BakerHostetler

New York State Department of Financial Services Publishes First Crypto Industry Consent Order

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​​​​​​​On August 1, 2022, the New York State Department of Financial Services (“DFS” or “Department”) issued a Consent Order, imposing a $30 million fine on Robinhood Crypto, LLC (“Robinhood”), a trading platform that allows...more

Sheppard Mullin Richter & Hampton LLP

NYAG’s Warning to Crypto Businesses Muddies Regulatory Waters; Compliance Requirements Remain Elusive

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New York’s chief law enforcement agency recently squandered an opportunity to bring much needed guidance to the digital assets space. On October 18, 2021, the Office of New York Attorney General, Letitia James (“NYAG”),...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

Perkins Coie

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

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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

Eversheds Sutherland (US) LLP

OFAC sanctions virtual currency exchange and updates ransomware advisory

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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

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

Katten Muchin Rosenman LLP

Bridging the Week - December 2018

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A federal judge said that it is not a violation of federal law for a trading firm and its chief executive officer to be smarter than their counterparties in ruling against the Commodity Futures Trading Commission in an...more

Fenwick & West LLP

SEC Enforcement Trends: Highlights from Securities Enforcement Forum West 2018

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The Securities Enforcement Forum West 2018 brought together current and former senior U.S. Securities and Exchange Commission and U.S. Department of Justice officials, securities enforcement and white-collar attorneys,...more

Orrick, Herrington & Sutcliffe LLP

Highlights From SEC Speaks 2018 - Retail, Cybersecurity And Cryptocurrency

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The Commissioners and senior officials of the Securities and Exchange Commission ("SEC" or "Commission") addressed the public on February 23-24 at the annual "SEC Speaks" conference in Washington, D.C. Throughout the...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - October 2017 #2

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FBI Issues Flash Alert on Apache Struts Vulnerability - The Apache Struts vulnerability has been mentioned frequently in the media over the past month, as it is believed to have been involved in one of the largest and most...more

Fenwick & West LLP

Securities Litigation and Enforcement Newsletter

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In this our second edition of Fenwick’s Securities Litigation and Enforcement Newsletter, we continue to provide you with short insights about timely securities litigation and enforcement developments. This edition’s topics...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - October 2015

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"Wherefore Art Thou Due Process?" Part III - Why it matters: It is time for another installment in our continuing "Wherefore Art Thou Due Process?" coverage into the ongoing constitutional challenges to the SEC's...more

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