Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry -
On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more
10/26/2021
/ Audits ,
Cryptocurrency ,
Cybersecurity ,
FinCEN ,
Internal Controls ,
Money Laundering ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Assessment ,
Sanctions ,
Testing Requirements ,
Training ,
U.S. Treasury ,
Virtual Currency
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks -
Amid...more
11/16/2020
/ Bitcoin ,
Cryptocurrency ,
Cyber Attacks ,
Department of Justice (DOJ) ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Enforcement Guidance ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Securities and Exchange Commission (SEC)
On Tuesday, June 4, 2019, the Trump administration announced tighter restrictions on trade with Cuba, which affects, among other things, a popular category of travel to Cuba for U.S. citizens. In the action, the U.S....more
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
On March 22, 2019, the Trump Administration initiated another round of sanctions against Venezuelan entities, sanctioning the Banco de Desarrollo Economico y Social de Venezuela (“Banco de Bandes”) as well as four other...more