On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying...more
3/8/2024
/ China ,
De Minimis Claims ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Entities ,
Russia ,
Sanctions ,
U.S. Commerce Department ,
U.S. Treasury
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
11/27/2023
/ Anti-Money Laundering ,
CFTC ,
Civil Monetary Penalty ,
Compliance ,
Crypto Exchanges ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement ,
Virtual Currency
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
On March 2, 2023, Deputy Attorney General Lisa Monaco delivered remarks to the ABA’s National Institute on White Collar Crime. Unsurprisingly, her remarks focused heavily on inspiring a culture of compliance – including...more
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
2/28/2023
/ Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions...more
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
After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran...more
On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons. These measures apply to the whole territory of the UK and to conduct by UK persons...more
On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more
On Sunday, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced novel and sweeping sanctions on specific categories of services in order to cripple Russia’s wartime capabilities and sanctioned key...more
5/12/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia
Last week, the United States government imposed additional restrictions on the imports from, and exports to, Russia. The import changes stem from the Suspending Normal Trade Relations with Russia and Belarus Act, signed into...more
4/14/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Imports ,
Russia ,
Supply Chain ,
Trade Relations ,
Trade Restrictions ,
Ukraine
Updated as of April 12, 2022 -
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more
4/13/2022
/ Asset Freeze ,
Belarus Sanctions ,
Economic Sanctions ,
EU ,
Export Controls ,
Financial Transactions ,
G7 ,
General Licenses ,
Investment ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trading Restrictions ,
UK ,
Ukraine
It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in...more
The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money...more
Updated as of February 25, 2022 -
Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions -
Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more
Updated as of February 25, 2022 -
Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions -
The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more
Last Friday, the Office of Foreign Assets Control (OFAC) published more targeted guidance for digital asset companies related to compliance with sanctions and best practices for mitigating risks. This guide comes on the heels...more
10/22/2021
/ Compliance ,
Cryptocurrency ,
Data Management ,
Digital Currency ,
Economic Sanctions ,
Financial Institutions ,
Financial Services Industry ,
Geolocation ,
IP Addresses ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Regulatory Oversight ,
Risk Management ,
Strict Liability ,
Virtual Currency
U.S.-Russia relations have been complicated, to say the least. Given Russia’s recent cyberattacks on SolarWinds and the government-directed attempts to influence the 2020 U.S. presidential election, the Biden administration...more
This week has been a week of significant foreign policy action. Today, President Biden issued a new Executive Order imposing tough sanctions on Russia for its interference in the U.S. 2020 presidential election, as well as...more
4/16/2021
/ Biden Administration ,
Cyber Attacks ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Russia ,
Sanctions ,
SolarWinds ,
Sovereign Debt ,
U.S. Treasury ,
US State Departments
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
1/16/2019
/ CAATSA ,
Economic Sanctions ,
Government Shutdown ,
Iran ,
Iran Sanctions ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Syria ,
Trump Administration ,
U.S. Treasury ,
Venezuela
A lot of us in the sanctions compliance world were wondering whether and when OFAC would issue official guidance on its application of sanctions in the digital currency world. On March 18, OFAC issued five FAQs related to...more
4/13/2018
/ Blocked Person ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Financial Instruments ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Requirements ,
SDN List ,
Token Sales ,
Virtual Currency
Since the U.S. government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. Twice in 2016, the United States implemented sanctions...more
Russian President Vladmir Putin has directed his government to develop a state-backed cryptocurrency, according to a Financial Times report published on January 2nd. A Putin advisor says that the “Crypto-rouble” could be used...more
1/11/2018
/ Anonymity ,
Anti-Money Laundering ,
Bitcoin ,
Blockchain ,
Criminal Investigations ,
Cross-Border Transactions ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Russia ,
Vladimir Putin
According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more
6/1/2017
/ Airlines ,
Corporate Counsel ,
Cuba ,
Economic Sanctions ,
Embargo ,
Foreign Relations ,
Infrastructure ,
Popular ,
State Sponsors of Terrorism ,
Telecommunications ,
Travel Ban ,
Trump Administration ,
US Trade Policies