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Cryptocurrency Loper Bright Enterprises v Raimondo

Ballard Spahr LLP

Anti-Money Laundering Aspects of the GENIUS Act

Ballard Spahr LLP on

On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more

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

Foley Hoag LLP - White Collar Law &...

SEC Expected to Shift Priorities and Adopt a More Business-Friendly Approach in 2025

This is the fourth in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

Snell & Wilmer

SEC Reporting Update - December 2024

Snell & Wilmer on

Insider Trading Policies. As previously discussed in our Winter 2022-2023 Corporate Communicator, the Securities and Exchange Commission (“SEC”) adopted final rules in December 2022 relating to insider trading policy...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

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

BakerHostetler

Victory for Tornado Cash as Court Rules Sanctions Were Unlawful

BakerHostetler on

On November 26, 2024, in a three-judge panel decision, Van Loon v. U.S. Department of the Treasury, the United States Court of Appeals for the Fifth Circuit (Court) reversed a Texas district court and held that immutable...more

Morgan Lewis

Fifth Circuit Rejects OFAC’s Tornado Cash Sanctions

Morgan Lewis on

In a ruling eagerly awaited by the cryptocurrency industry, the US Court of Appeals for the Fifth Circuit held that immutable smart contracts on the Tornado Cash crypto-transaction software protocol are not “property” subject...more

The Wagner Law Group

Election 2024: ERISA and the Proposed New Labor Secretary – Look(ing) for the Union Label?

The Wagner Law Group on

President-Elect Trump has proposed Rep. Lori Chavez-DeRemer as the next Secretary of Labor. The selection is particularly notable for the clear pro-union leanings of the nominee of a Republican president-elect. Any effort...more

Morrison & Foerster LLP

What to Expect from the SEC During a Second Trump Administration?

Morrison & Foerster LLP on

Given the recent news about President-Elect Trump’s cabinet appointments , it is a safe bet that the SEC Division of Enforcement’s priorities will change under the new administration. Under President Biden, SEC Chair Gary...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

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