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Cryptocurrency › Chevron Deference

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

BCLP on

Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

Bracewell LLP

An "Immutable" Force Meets an Immovable Object: OFAC's Crypto Loss at the Fifth Circuit

Bracewell LLP on

On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more

Mayer Brown

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

Mayer Brown on

On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

Vinson & Elkins LLP

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

Vinson & Elkins LLP on

On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Wiley Rein LLP

Introducing Wiley’s Trump Administration Resource Center & Guide – Your Essential Tools for 2025

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As President-Elect Trump’s second Administration begins in January 2025, businesses face a critical juncture with potential shifts in regulatory focus across industries and sectors including artificial intelligence,...more

Mintz - ML Strategies

2024 Post-Election Analysis

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Following a hotly contested election, Donald Trump is once again the president-elect and will return to the White House on January 20, 2025. He will do so with a dominant electoral college win, potentially a win of the...more

Crunched Credit

Regulatory Contagion

Crunched Credit on

Last year, I wrote a commentary entitled Contagion.  That commentary was inspired by the early days of the meltdown of the crypto currency market (long before SBF made the whole space way more notorious with a whiff of...more

Katten Muchin Rosenman LLP

Financial Markets and Funds Quick Take | Issue 28

Katten Muchin Rosenman LLP on

Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds....more

Latham & Watkins LLP

US Supreme Court Curtails Agency Power: Implications for Fintech and Crypto

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Recent Supreme Court administrative law rulings change the power dynamic between the executive and the judiciary in critical areas of statutory interpretation, enforcement, and immunity from legal challenge....more

Fenwick & West LLP

Treasury’s Crypto Tax Reporting Rules Defer on DeFi

Fenwick & West LLP on

On June 28, 2024, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final broker reporting regulations that mandate broker reporting for centralized exchanges and hosted wallet providers, providing...more

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