On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more
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
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
Yesterday, on November 28, 2022, the Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement agreement with Payward, Inc. (Kraken), an online virtual currency exchange, in connection with 826 apparent...more
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 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
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
U.S. Comprehensive Sanctions Against the DNR and the LNR -
Scope: the DNR and LNR -
The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more
2/22/2022
/ Biden Administration ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
International Trade ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
UK ,
Ukraine ,
United States ,
Vladimir Putin
The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more
11/17/2021
/ Compliance ,
Cryptocurrency ,
Cyber Crimes ,
Enforcement Actions ,
Financial Transactions ,
Non-Fungible Tokens (NFTs) ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Sanctions ,
SDN List ,
U.S. Treasury
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
On September 21, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According...more
Since President Biden took office and put his national security team in place, we have wondered about the future of the Iran Nuclear Deal. In the past weeks, the Biden Administration has taken formal steps to possibly restore...more
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
What does decertification mean?
For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more
10/13/2017
/ Automotive Industry ,
Banking Sector ,
Energy Sector ,
Financial Transactions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping ,
Sovereign Debt
On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the...more
1/13/2017
/ Amended Legislation ,
Barack Obama ,
Bipartisan Agreement ,
Cyber Attacks ,
Cyber Sanctions ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Legislative Agendas ,
Office of Foreign Assets Control (OFAC) ,
Pending Legislation ,
Presidential Elections ,
Russia ,
Trump Administration ,
Vladimir Putin
With fewer than 100 days left in office, President Obama is not slowing down on his efforts to normalize relations between the United States and Cuba. Today, several changes to the Cuban Assets Control Regulations (CACR) and...more
10/18/2016
/ Aviation Industry ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Energy Sector ,
Export Administration Regulations (EAR) ,
Exports ,
Imports ,
Medical Research ,
Office of Foreign Assets Control (OFAC) ,
Travel
In late May, The Russian Federation issued its first sovereign bond since the Ukraine crisis in 2014. The sole organizer of the bond is VTB Capital, an arm of VTB Bank, Russia’s second largest financial institution. Both VTB...more