News & Analysis as of September 22, 2024

Virtual Currency › Economic Sanctions

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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 -

The Shadow Financial System

White & Case LLP on 6/18/2024

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Morrison & Foerster LLP on 3/5/2024

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....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

[Event] 24th National Forum on Prepaid Accounts Compliance - April 8th, New York, NY

American Conference Institute (ACI) on 1/29/2024

The 24th National Forum on Prepaid Accounts Compliance will address the latest developments impacting the prepaid industry and provide answers to the most pressing questions and challenges being faced by practitioners in this...more

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

Lowenstein Sandler LLP on 1/12/2024

On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

Foodman CPAs & Advisors on 11/29/2023

El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more

Terrorist Financing FinCEN Red Flags

Foodman CPAs & Advisors on 11/29/2023

On 10/20/23, Terrorist Financing Red Flags were issued by FinCEN to assist financial institutions in identifying funding streams for the terrorist organization Hamas in response to Hamas’s terrorist attack on the people of...more

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

Sheppard Mullin Richter & Hampton LLP on 11/27/2023

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

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

OFAC sanctions actors facilitating DPRK virtual currency laundering

Orrick, Herrington & Sutcliffe LLP on 4/27/2023

On April 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Orders 13722 and 13382, against three individuals for providing material support to the Democratic...more

Navigating the International Trade & National Security Landscape

Foley Hoag LLP on 4/21/2023

The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more

OFAC Finds Digital Assets Trading Platform in Violation of Sanctions

Sheppard Mullin Richter & Hampton LLP on 4/5/2023

On March 31, 2023, the Office of Foreign Assets Control (OFAC) announced a $72,230.32 settlement agreement with Uphold HQ Inc. (Uphold), a global multi-asset digital trading platform, in connection with 152 apparent...more

OFAC Year in Review 2022 – Part 1

Morrison & Foerster LLP on 3/2/2023

2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more

International Trade Law: 2022 Year in Review & Outlook for 2023

Husch Blackwell LLP on 1/9/2023

We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might...more

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

The Volkov Law Group on 12/9/2022

Cryptocurrency companies are in trouble. Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more

OFAC Settles With Kraken for $362,158: Maximum Penalty Avoided

Troutman Pepper on 12/2/2022

On November 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement with Payward, Inc. d/b/a Kraken. The Delaware-incorporated virtual currency exchange allegedly...more

Kraken Settlement Demonstrates Importance of Sanctions Monitoring for Transactions — Not Just When Onboarding Customers

Ballard Spahr LLP on 11/30/2022

The Office of Foreign Assets Control (“OFAC”) announced (here and here) yesterday that virtual currency exchange Payward, Inc. – better known as Kraken – has agreed to pay $362,158.70 in order to settle its potential civil...more

Crypto Company Comes Under OFAC Scrutiny

Holland & Knight LLP on 10/25/2022

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 11, 2022, announced a more than $24.28 million settlement with Bittrex Inc. (Bittrex), a Bellevue, Washington-based company that offers...more

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

Ballard Spahr LLP on 10/21/2022

The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...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 Announces Hefty Settlement with Virtual Currency Exchange / Hosted Wallet Services Provider

Sheppard Mullin Richter & Hampton LLP on 10/12/2022

Settlement Agreement with Bittrex, Inc. Today, on October 11, 2022, the Office of Foreign Assets Control (OFAC) announced a $24,280,829.20 settlement agreement with Bittrex, Inc., an online virtual currency exchange and...more

Civil Complaint Challenges OFAC’s Tornado Cash Sanctions

Ballard Spahr LLP on 9/16/2022

Last month, the Office of Foreign Assets Control (“OFAC”) sanctioned Tornado Cash, a virtual currency “mixer” operating on the Ethereum blockchain which allegedly has been used to launder the virtual currency equivalent of...more

5 Things to Know About OFAC Sanctioning Crypto Mixer Tornado Cash

Orrick, Herrington & Sutcliffe LLP on 8/10/2022

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned the popular decentralized virtual currency mixer Tornado Cash on August 8, 2022, continuing the U.S. government’s efforts to target...more

[Webinar] Recent Trends in the U.S. Department of Justice’s International Criminal Investigations - September 8th, 9:00 am - 10:00...

Paul Hastings LLP on 7/26/2022

Discussion with two former senior prosecutors on how to handle cases involving Japanese multinational corporations - It is not unusual for the U.S. Department of Justice to investigate non-U.S. multinational corporations...more

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Virtual Currency › Economic Sanctions

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