News & Analysis as of September 22, 2024

Office of Foreign Assets Control (OFAC)

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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

Implications of FinCEN’s Notice of Proposed Rulemaking on Virtual Currency Mixers

K2 Integrity on 1/29/2024

On 17 January 2024, K2 Integrity hosted a webinar on FinCEN’s Notice of Proposed Rulemaking on virtual currency mixers and the implications of this first-of-its-kind 311 designation on the virtual currency industry. Elizabeth...more

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - December 2023

Lowenstein Sandler LLP on 12/11/2023

TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

Sheppard Mullin Richter & Hampton LLP on 12/4/2023

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

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

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on 11/14/2023

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

FinCEN Targets Convertible Virtual Currency Mixing to Combat Terrorist Financing and Other Illegal Transactions

Morrison & Foerster LLP on 10/27/2023

Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - October 2023 # 4

Troutman Pepper on 10/25/2023

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...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

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

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

Skadden, Arps, Slate, Meagher & Flom LLP on 11/16/2022

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...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

Top PHive Crypto Enforcement Notes: September Edition

Paul Hastings LLP on 9/7/2022

Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

OFAC Sanctions Virtual Currency “Mixer” Tornado Cash and Faces Crypto Backlash

Ballard Spahr LLP on 8/25/2022

On August 8, the U.S. Department of the Office of Foreign Assets Control (“OFAC”) sanctioned “notorious” virtual currency “mixer” Tornado Cash, which allegedly has been used to launder more than $7 billion worth of virtual...more

Sanctions Against Russia: The Week in Review - April 2022 - 3

K2 Integrity on 4/27/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our regular reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more

OFAC Designates “Hydra” – the Largest Darknet Market – and Third Russian Virtual Currency Exchange

Ballard Spahr LLP on 4/7/2022

On April 5, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against “the world’s largest and most prominent darknet market, Hydra Market” and Garantex, a virtual...more

FinCEN Provides Reminder About BSA Reporting Requirements

Freeman Law on 3/30/2022

FinCEN and Bank Secrecy Act Reporting - On March 7, 2022, the Financial Crime Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury alerted financial institutions “to be vigilant against efforts to...more

FinCEN warns financial institutions to be “vigilant” for Russia sanctions violations

Eversheds Sutherland (US) LLP on 3/21/2022

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more

Sanctions Against Russia: The Week in Review - March 2022

K2 Integrity on 3/18/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

Harris Beach PLLC on 3/15/2022

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

Year-end Crypto Roundup — Five Key Concepts About the U.S. Government’s Recent Actions on Virtual Currency and Ransomware

Orrick, Herrington & Sutcliffe LLP on 12/30/2021

The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more

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Virtual Currency › FinCEN › Office of Foreign Assets Control (OFAC)

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