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FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

FinCEN Proposes To Designate Convertible Virtual Currency Mixing as a Primary Money Laundering Concern

The Proposed Rule Aims To Increase Transparency in CVC Mixing - On October 19, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a notice of proposed rulemaking (Proposal)...more

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

In Coordinated Action, US Authorities Increase Russia-Related Restrictions and Warn About Evasion Risks

Through a series of coordinated actions in May 2023, the United States launched a whole-of-government effort to expand and strengthen enforcement of its sanctions campaign against Russia as the conflict in Ukraine continues...more

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

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

Recent Actions by the Fed Show Its Continued Cautious Approach to Cryptoasset Activities by Supervised Institutions

In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more

US Regulators Express Concern About Banks’ Exposure to Cryptoasset Risks

On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued a Joint Statement on...more

Why Directors and Executives Need To Pay Attention to Sanctions, Money Laundering and Export Rules

Recent developments, including Russia’s invasion of Ukraine, ongoing tensions between the U.S. and China, and turmoil in the digital assets sector, have made it essential for companies — including their directors and senior...more

Price Cap on Russian Crude Oil Becomes Effective

On December 5, 2022, the price cap on Russian crude oil that was announced by the G-7 finance ministers in September 2022 went into effect at a level of $60 per barrel. The price cap is implemented by prohibiting the...more

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Revisions to the DOJ’s Corporate Criminal Enforcement Policy Will Require Companies To Reevaluate Their Compliance Systems

In a recently published memorandum, Deputy Attorney General (DAG) Lisa Monaco announced important updates to the U.S. Department of Justice’s (DOJ’s) approach to investigating and prosecuting corporate crimes. In the...more

House Bill To Revise Community Reinvestment Act Would Put New Focus on Fair Lending

Legislation introduced on September 15, 2022 by Maxine Waters (D-Cal.), chair of the House Committee on Financial Services, would significantly revise the Community Reinvestment Act (CRA), adding a number of new substantive...more

Treasury and Justice Department Reports Signal Tougher Enforcement and Regulation in the Digital Assets Sector

On September 16, 2022, the U.S. Department of the Treasury and Department of Justice released four much-anticipated reports on different aspects of cryptoasset regulation. They confirm the Biden administration’s broad but...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts

A flurry of legal and enforcement activity has arisen over the last two weeks across a wide range of areas in the Web3 space, including actions by the Securities and Exchange Commission, the Office of Foreign Assets Control,...more

Regulatory Actions and Legislative Proposals Signal Growing Consensus on Parameters for Stablecoins

Recent guidance from the New York State Department of Financial Services (DFS) and a proposed bill in the U.S. Senate portend more regulatory and legislative activity to clarify the status of and requirements for stablecoin...more

Revisions to CRA Would Fundamentally Alter Measures of Bank Performance

On May 5, 2022, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together the Agencies) released a joint notice of proposed...more

Toomey Introduces Proposal for Payment Stablecoin Regulatory Framework ...

On April 6, 2022, Sen. Pat Toomey (R-Pa.), the ranking member of the Senate Banking Committee, and an advocate for clarity in cryptocurrency regulations, released a discussion draft of legislation that would provide a...more

New US Restrictions Impact Russia-Related Imports and Exports, US Dollar-Denominated Banknotes

On March 11, 2022, President Joe Biden signed Executive Order 14068 (E.O. 14068) imposing new restrictions on imports and exports with respect to Russia as well as on the supply of U.S. dollar-denominated banknotes to the...more

District Court Upholds OCC and FDIC ‘Valid When Made’ Rules

On February 8, 2022, a federal district court in California issued two opinions, granting summary judgment to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) and...more

The Federal Reserve Weighs Risks and Benefits of a US Central Bank Digital Currency

This is the fourth in a series of articles in which we discuss recent efforts by regulators and other governmental bodies to set expectations and standards, or pursue governmental initiatives, with respect to cryptocurrencies...more

Federal Regulators Move To Regulate Stablecoins Through Banking Laws Plus New Legislation

The President’s Working Group on Financial Markets (PWG), together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a much-anticipated Report on...more

FATF Updates Its Global Guidelines for the Regulation of Virtual Assets With an Eye to Emerging Technologies

On October 28, 2021, the Financial Action Task Force (FATF), the international body that sets standards for anti-money laundering and countering the financing of terrorism (AML/CFT), released updated guidance addressing the...more

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