News & Analysis as of

Cryptocurrency Sanctions U.S. Treasury

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

Skadden, Arps, Slate, Meagher & Flom LLP

Court Victory for Treasury and Indictment of Tornado Cash Founders Highlights AML and Sanctions Risks for DeFi Crypto Platforms

In a long-awaited decision involving the cryptocurrency “mixer” Tornado Cash, a U.S. district court on August 17, 2023, upheld the broad authority of the Department of the Treasury’s (Treasury’s) Office of Foreign Assets...more

Sheppard Mullin Richter & Hampton LLP

Treasury Department Seeks to Coordinate Globally on Crypto Regulation

On July 7, 2022, the Treasury Department laid out how it would work with its overseas counterparts and in international forums as the U.S. studies cryptocurrencies to set up a possible regulatory regime. This framework is the...more

Akin Gump Strauss Hauer & Feld LLP

Treasury to Companies: Time to Take Ransomware Reporting Seriously

On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more

Sheppard Mullin Richter & Hampton LLP

OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key

The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...more

Akin Gump Strauss Hauer & Feld LLP

Treasury Publishes U.S. Sanctions Policy Review and Framework for Future Action

On October 18, 2021, the U.S. Treasury Department released a long awaited report on its first of its kind “top to bottom” review of U.S. economic and financial sanctions. The report does not make or recommend any immediate or...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Department of the Treasury Publishes Sanctions Review Results

On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on

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

Bracewell LLP

OFAC Ransomware Update

Bracewell LLP on

On Friday, OFAC published a compliance guide aimed at the virtual currency industry, which promotes sanctions compliance amid the rise of ransomware attacks. Similar to OFAC’s recent advisory, this compliance guide is yet...more

Sheppard Mullin Richter & Hampton LLP

Do You Have a Risk-Based Sanctions Compliance Program?: In the Event of a Ransomware Attack, OFAC Wants to Know

In the wake of increased ransomware attacks over the course of the last several months, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has updated a guidance it released last year on potential...more

Davis Wright Tremaine LLP

OFAC Makes Waves in Fight Against Ransomware, but Practical Effects Unclear

On September 21, 2021, the U.S. Department of the Treasury announced two major actions by the Office of Foreign Asset Control (OFAC) to combat ransomware: the release of OFAC's Updated Advisory on Potential Sanctions Risks...more

K2 Integrity

OFAC Releases Updated Ransomware Advisory and Announces First Designation of Cryptocurrency Exchange

K2 Integrity on

On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...more

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