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FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more

Beware: Increasingly Aggressive Enforcement Actions in the Crypto Asset Industry Puts Companies on Notice

Regulators are increasingly taking enforcement action against crypto asset industry participants for violating anti-money laundering (AML) and sanctions laws. Regulators are concerned about the illicit use of crypto...more

OFAC Penalizes Another Crypto Asset Company for Sanctions Violations

In keeping with its recent focus on the crypto asset industry, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced an agreement last week with crypto asset trading platform Poloniex, LLC...more

FinCEN Issues ‘First-of-its-Kind’ Order Against Crypto Asset Exchange Linked to Illicit Russian Activity

On January 18, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) designated Bitzlato Limited (Bitzlato), a crypto asset exchange business incorporated in Hong Kong, as a “primary money...more

Coinbase Agrees to Pay $100 Million and Improve Compliance Program as Regulators Continue Scrutiny of Crypto Asset Companies

The consent order issued by the New York Department of Financial Services (NYDFS) to crypto asset exchange, Coinbase, serves as a reminder of regulators’ growing interest in ensuring that crypto asset companies meet their...more

Crypto Exchange Agrees to Pay More Than $362,000 to Settle Alleged Sanctions Violations

On November 28, 2022, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Payward, Inc. d/b/a Kraken, a U.S.-based cryptocurrency exchange, agreed to pay $362,158.70 to settle charges relating to its...more

Focus on Fintech - Q3 2022

Welcome to Wilson Sonsini’s Focus on Fintech newsletter. This quarterly newsletter provides ongoing analysis and commentary on regulatory developments impacting the fintech industry. The third quarter of 2022 has been a...more

Cryptocurrency Exchange Platform Agrees to Pay over $53 Million for Anti-Money Laundering and Sanctions Violations

On October 11, 2022, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced settlements with Bittrex Inc. (Bittrex). The settlements arise from violations of...more

Money Services Businesses Penalized for Failure to Adopt Robust Anti-Money Laundering Practices

Two recent federal enforcement actions—announced the same day—have underlined the need for crypto companies to carefully consider their anti-money laundering (AML) obligations or else risk significant penalties....more

New OFAC Guidance Raises the Stakes for Crypto Industry

The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) published new guidance last week for the virtual currency industry. While OFAC's economic sanctions compliance obligations apply to all U.S. persons, the...more

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