News & Analysis as of September 22, 2024

Anti-Money Laundering

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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 -

CryptoLink - December 2023 Updates

Akin Gump Strauss Hauer & Feld LLP on 1/19/2024

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

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

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on 12/8/2023

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

Kelley Drye & Warren LLP on 11/27/2023

On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

Wilson Sonsini Goodrich & Rosati on 11/8/2023

On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more

In the First Use of Its Section 9714 Powers, the U.S. Treasury Designated Bitzlato as a Russian-Linked Primary Money Laundering...

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2023

On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more

FinCEN prohibits engagement with virtual currency exchange connected to Russian finance

Orrick, Herrington & Sutcliffe LLP on 1/20/2023

On January 18, the Financial Crimes Enforcement Network (FinCEN) issued its first order pursuant to section 9714(a) of the Combating Russian Money Laundering Act to identify a Hong Kong-registered global virtual currency...more

Daily Financial Regulation Update -- Thursday, January 19, 2023

Paul Hastings LLP on 1/20/2023

January 18, 2023- The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an order that identifies the virtual currency exchange Bitzlato Limited (Bitzlato) as a "primary money laundering...more

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

Bracewell LLP on 10/27/2021

In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on 10/25/2021

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

OFAC Imposes New Sanctions to Thwart Ransomware

WilmerHale on 9/24/2021

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on 7/7/2021

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

SEC Action Could Have Rippling Effects on Future of Cryptocurrency

Snell & Wilmer on 2/24/2021

Many investors, traditional and progressive, are looking hard at cryptocurrency investments as a way to diversify their portfolios. However, there are still multiple known “unknowns” about this new market, including the...more

Financial Services: What’s Next Under the Biden Administration?

Pillsbury Winthrop Shaw Pittman LLP on 2/9/2021

Pillsbury partner and Public Policy group leader Elizabeth Vella Moeller recently sat down with Matthew McGuire, former Executive Director of the World Bank under President Obama, to discuss the Biden administration’s...more

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on 1/18/2021

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

Legislative Reform Will Reinvent the US Anti-Money Laundering Regulatory Landscape

Pillsbury Winthrop Shaw Pittman LLP on 1/6/2021

New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more

Virtual Currency as a Threat to National Security?

King & Spalding on 3/12/2020

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

Ballard Spahr LLP on 3/5/2020

In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

Developments in Cryptocurrency in 2018

Akin Gump Strauss Hauer & Feld LLP on 9/24/2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

Rapidly Shifting Regulatory Landscape for Virtual Currencies | Market Participants: Stay Tuned

McDermott Will & Emery on 3/27/2018

As US regulators have been active in terms of virtual currency regulation, there are three important updates to which attention should be paid. The New York State DFS guidance, the FinCEN letter to Senator Wyden and the...more

Your Daily Dose of Financial News

Robins Kaplan LLP on 3/13/2018

Notwithstanding Lloyd’s assurances that the rumors of his demise are premature, Goldman has cleared the path forward for David Solomon (aka, one of its current co-Presidents, aka, DJ D-Sol) to assume the CEO position when Mr....more

Blockchain Week in Review – January 2018

Perkins Coie on 1/31/2018

U.S. Developments - Regulatory Updates - CFTC and SEC Enforcement Directors Issue Joint Statement Regarding Virtual Currency Enforcement Actions - This morning, the Enforcement Director of the U.S. Commodity...more

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