On March 5, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced charges and a corresponding cease-and-desist order (the “Order”) with ShapeShift AG, a cryptocurrency exchange registered in Switzerland that...more
In Part I, we discussed the basics behind the UK Modern Slavery Act of 2015. To briefly reiterate, that Act requires any company doing business in the UK with an annual turnover of £36 million or more to publicize their...more
3/12/2024
/ Compliance ,
Corporate Governance ,
Corporate Social Responsibility ,
Corruption ,
Forced Labor ,
Human Rights ,
Human Trafficking ,
Modern Slavery Act ,
Risk Management ,
Supply Chain ,
UK
Easy come, easy go. On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...more
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs....more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
12/19/2023
/ Compliance ,
Corruption ,
Crimea ,
Crypto Exchanges ,
Cryptocurrency ,
Economic Sanctions ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanction Violations ,
Ukraine ,
White Collar Crimes
Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more
11/8/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief. Specifically, OFAC issued General License 44 (among...more
11/7/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more
On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions. The relief includes General Licenses...more
10/23/2023
/ Compliance ,
Corruption ,
Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Relief Measures ,
Venezuela ,
White Collar Crimes
Unsurprisingly, we’ve been fielding a significant number of inquiries regarding the latest Russian sanctions. Most companies seek black and white answers – what can we do and what can’t we do. However, sanctions are very...more
In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry. For seasoned compliance veterans, it ends up reading like a refresher...more
In December 2020, three days before Christmas, the SEC filed a significant case against Ripple, the major cryptocurrency company. Ripple is a major cryptocurrency company, utilizing the technology to create a global digital...more
1/13/2021
/ Accredited Investors ,
Compliance ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Offering Fraud ,
Popular ,
Ripple ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations ,
Unregistered Securities
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more
11/3/2020
/ BitMEX ,
CFTC ,
Compliance ,
Corruption ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
Financial Transactions ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Initial Coin Offering (ICOs) ,
IRS ,
Know Your Customers ,
Money Laundering ,
OCC ,
Popular ,
Securities and Exchange Commission (SEC) ,
Virtual Currency ,
White Collar Crimes
On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604. With little fanfare, the interim rule published in the Federal Register greatly expands the...more
Many organizations struggle with their internal culture for a variety of reasons. Establishing a strong and compliant corporate culture is paramount for an effective compliance program, as even the DOJ has harped on in its...more
Just this month, former CFTC Chairman Timothy G. Massad released a report through the Brookings Institution entitled “It’s Time to Strengthen the Regulation of Crypto-Assets.” ...more
3/26/2019
/ Bitcoin ,
CFTC ,
Compliance ,
Cryptoassets ,
Cryptocurrency ,
Cyber Attacks ,
Ethereum ,
Financial Markets ,
Investment Opportunities ,
Regulatory Agenda ,
Regulatory Oversight
You’ve heard this before, but it still holds true – cryptocurrency regulations are coming. Everyone knows they’re inevitable, and there has been some trepidation amongst investors that regulations will disrupt innovation and...more
3/15/2019
/ Bitcoin ,
Compliance ,
Crypto Exchanges ,
Cryptocurrency ,
Digital Currency ,
Financial Markets ,
Hackers ,
Initial Coin Offering (ICOs) ,
Investment Opportunities ,
Money Laundering ,
Money Transmitter ,
Ponzi Scheme ,
Regulatory Standards ,
Token Sales ,
Virtual Currency