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CryptoLink Newsletter - September 2025 Updates

Federal funding from the full-year Continuing Resolution (CR) expired on September 30. Without the necessary votes in the Senate to pass a clean CR, the federal government shut down on October 1. Since then, most official...more

BIS Publishes 50% 'Affiliates Rule'

On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) posted, for public inspection, an interim final rule titled “Expansion of End-User Controls to Cover Affiliates of Certain Listed...more

CryptoLink - August 2025

The push for digital assets legislation has slowed since its peak in July, largely due to Congress's August recess and its current focus on essential funding and defense authorization bills. However, the Senate Banking...more

CryptoLink Newsletter - July 2025 Updates

President Trump signed the GENIUS Act into law the following day. Ahead of the annual August recess, Senate Banking Committee Chairman Tim Scott (R-SC), along with Senators Cynthia Lummis (R-WY), Bill Hagerty (R-TN) and...more

DOJ and DHS Launch Cross-Agency Task Force to Combat Trade Fraud

On August 29, 2025, the U.S. Departments of Justice (DOJ) and Homeland Security (DHS) announced the creation of a new cross-agency Trade Fraud Task Force “to bring robust enforcement against importers and other parties who...more

Tariff Evasion and Customs Fraud Under the Microscope: DOJ Signals Aggressive Criminal Enforcement Ahead

Given the Trump Administration’s unprecedented reliance on tariffs as a foreign policy tool and a means to protect and foster U.S. industry, the U.S. Department of Justice (DOJ) is rapidly shifting resources and enforcement...more

CryptoLink - June 2025

June marked a pivotal moment in U.S. digital asset oversight with major developments from the SEC, Congress, and the DOJ. First, on June 9, 2025, the SEC’s Crypto Task Force held its final scheduled roundtable called “DeFi...more

CryptoLink - May 2025

In May 2025, the leadership from the SEC provided guidance on digital asset regulation in several keynote addresses and round tables. The SEC's activities in May 2025 suggest a deliberate movement towards establishing a more...more

Acquirors Beware: PE Firm Escapes DOJ Prosecution, but Acquired Entity Hit With $2 million+ in Penalties

In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy.  Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more

DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more

CryptoLink - April 2025

Following a two-week Easter recess at the end of April, Congress returned to Washington, D.C. with all eyes on budget reconciliation. Individual committees marked up legislation in accordance with reconciliation directives to...more

DOJ’s Criminal Division Turns Page on White Collar Crime—But Keeps One Foot in the Past

On May 12, 2025, the DOJ announced a new “white-collar enforcement plan” identifying new corporate enforcement priorities and aiming to promote greater focus, fairness and efficiency in prosecuting corporate misconduct. In a...more

The European Response to DOJ’s FCPA Enforcement “Pause”

On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more

CryptoLink - February 2025 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

CryptoLink - January 2025 Updates

Both the CFTC and SEC have new Acting Chairs, who are known to be crypto advocates, with Mark Uyeda being appointed Acting Chair of the SEC, taking over from Gary Gensler, while Caroline D. Pham has assumed the role of Acting...more

Analyzing the Attorney General’s FCPA Enforcement Shift

UPDATE: President Signs Executive Order Directing DOJ to Pause All FCPA Enforcement for 180 Days - On February 10, 2025, President Trump issued an Executive Order directing the U.S. Department of Justice (DOJ) to pause all...more

CryptoLink - December 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Supreme Court Narrows Federal Bribery Statute That Applies to State and Local Officials

On June 26, 2024, the U.S. Supreme Court held 6-3 in Snyder v. United States that a federal statute, 18 U.S.C. § 666(a)(1)(B), does not criminalize “gratuities” to state and local officials—i.e., payments made to those...more

OFAC Revamps Reporting Requirements

Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more

Congress Extends Statute of Limitations for Sanctions and Certain Other National Security Programs from 5 to 10 Years and...

While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more

DOJ National Security Division Updates Corporate Crime Enforcement Policy and Issues Whistleblower Policy

Executive Summary - - On March 7, 2024, the NSD of the DOJ issued an updated NSD Enforcement Policy to include a new section covering VSDs in connection with mergers and acquisitions. - These updates follow repeated...more

Commerce Issues Proposed Rule on “Malicious Cyber-Enabled Activities” and Artificial Intelligence

On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule (the Proposed Rule) that would impose significant know-your-customer (KYC), monitoring and reporting obligations...more

BIS Announces Key Updates to Voluntary Self-Disclosure Process

Key Points - On January 16, 2024, Matthew Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s BIS announced key updates to BIS’s VSD process. The updates are also now reflected on BIS’s...more

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