Despite the Trump administration’s generally favorable stance toward cryptocurrency and blockchain innovation, virtual asset services providers (VASPs) must remain vigilant in complying with anti-money laundering (AML)...more
4/7/2025
/ Anti-Money Laundering ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Popular ,
Risk Assessment ,
Risk Management ,
Trump Administration ,
Virtual Currency
On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more
2/3/2025
/ Anti-Money Laundering ,
Cartels ,
Department of Justice (DOJ) ,
Drug Trafficking ,
Financial Crimes ,
Financial Institutions ,
Foreign Trade Regulations ,
Know Your Customers ,
Mexico ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Terrorist Financing Regulations ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury
President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more
1/31/2025
/ Anti-Money Laundering ,
CFTC ,
Compliance ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
On December 3, 2024, the District Court for the Eastern District of Texas issued an order implementing a nationwide preliminary injunction of the Corporate Transparency Act and its enforcement. The court also stayed the...more
In this update, we focus on the potential changes in the executive branch and on the congressional committees that have jurisdiction over cryptocurrency. As the transition unfolds, much attention is on who will stay from the...more
11/25/2024
/ Anti-Money Laundering ,
Board of Governors ,
Choke Point ,
Cryptocurrency ,
Digital Assets ,
Economic Action Plan ,
Executive Branch ,
FDIC ,
Federal Reserve ,
Financial Services Committee ,
Financial Services Industry ,
FinTech ,
GAO ,
NDAA ,
OCC ,
Secretary of the Treasury ,
Securities and Exchange Commission (SEC) ,
Trump Administration
This week, FinCEN issued new FAQs interpreting the obligations of the Corporate Transparency Act (“CTA”) that would require entities that were dissolved prior to the due date of the beneficial ownership initial report (“BOI...more
On February 13, 2024, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would apply comprehensive anti-money laundering and countering the financing of terrorism...more
On January 12, 2024, FinCEN updated its interpretations of the Corporate Transparency Act (“CTA”) that potentially will have a significant impact on private equity firms. This alert provides an overview of the CTA and certain...more
On October 19, FinCEN announced its determination that transactions with foreign operating crypto-mixers, a service that obfuscates the source and destination of transactions on a public blockchain, are of “Primary Money...more
On April 6, 2023, Treasury issued its risk assessment for decentralized financial (“DeFi”) services as required by Executive Order 14067. While not guidance, the Risk Assessment can provide some insight into Treasury’s views...more
Happy New Year! While the holidays hopefully provided a chance to rest and recharge, things have not slowed down in the world of digital asset enforcement. We see a growing dedication of resources by government law...more
1/13/2023
/ Bank Secrecy Act ,
CFTC ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
FDIC ,
FinCEN ,
Fraud ,
Ponzi Scheme ,
Popular ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Suspicious Activity Reports (SARs) ,
Wire Fraud
Well, it was another quiet month in crypto . . . Not. We are still watching the tsunami play out in real time, as governments and the crypto market react to another seismic shift in the crypto landscape....more
12/8/2022
/ Asset Seizure ,
Bitcoin ,
Blockchain ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Convictions ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Fraud ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Securities and Exchange Commission (SEC)
It certainly feels like a race between innovation and enforcement these days, with regulators and law enforcement stepping up the cautionary rhetoric and promising broader enforcement aimed at corporate actors....more
11/4/2022
/ Blockchain ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FDIC ,
FHFA ,
FinCEN ,
NCUA ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
We knew there would be plenty to write about each month, and so we start with a mention of the White House’s Framework for Responsible Development of Digital Assets, issued on September 16, 2022....more
10/4/2022
/ CFTC ,
CID ,
Commodity Exchange Act (CEA) ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Federal Trade Commission (FTC) ,
FinTech ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
SAR ,
SDN List ,
U.S. Treasury ,
Unregistered Securities
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
9/7/2022
/ Anti-Money Laundering ,
CEOs ,
Certifications ,
Chief Compliance Officers ,
Chief Information Security Officer (CISO) ,
Compliance ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Enforcement ,
FinCEN ,
MSB ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Suspicious Activity Reports (SARs) ,
Virtual Currency