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Non-U.S. Crypto and Other Money Services Businesses: Have Customers in the U.S.? Beware of AML and Sanctions Compliance Risk

Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more

Off‐Shore Crypto Exchange to Pay Up to $100 Million to Resolve Enforcement Action with U.S. Regulators

The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more

AML Enforcement Is a Key Tool to Combat Cryptocurrency Crimes

On October 8, 2020, the U.S. Attorney General’s Cyber-Digital Task Force released its Cryptocurrency Enforcement Framework. The Framework makes clear that, in addition to prosecuting bad actors who use cryptocurrency to...more

DOJ Demonstrates its Ability to Track Illegal Foreign Funds Laundered Through Crypto; Financial Institutions Must Keep Up

The Department of Justice (DOJ) announced last week and earlier this month civil forfeiture actions brought by the United States Attorney’s Office for the District of Columbia to seize stolen or laundered virtual currency...more

The United States' Danske Bank Investigation – This is Something Different

Earlier this month, Danske Bank A/S – Denmark's largest bank – announced that the United States Department of Justice ("DOJ") has initiated a criminal investigation relating to the bank's Estonian branch....more

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