News & Analysis as of

Office of Foreign Assets Control (OFAC) Economic Sanctions Appeals

Venable LLP

A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash

Venable LLP on

On March 21, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) officially lifted sanctions on Tornado Cash, the decentralized cryptocurrency mixer it had blacklisted in August 2022....more

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

Paul Hastings LLP on

Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...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

Oberheiden P.C.

Ten Strategic Considerations for OFAC Appeals

Oberheiden P.C. on

The Office of Foreign Assets Control (OFAC) has oversight of financial transactions involving U.S. and foreign entities. It exercises this authority in several ways, including (i) through the administration of its various...more

Fuerst Ittleman David & Joseph

D.C. Circuit: U.C.C. Article 4A Does Not Govern Judgment Creditors’ Claims to Sanctioned Company’s Funds Held by Intermediary...

On August 16, 2022, the United States Court of Appeals for the D.C. Circuit issued its ruling in Estate of Jeremy Isadore Levine, et al. v. Wells Fargo Bank, N.A., No. 21-7036, –F.4th– (D.C. Circuit August 16, 2022), a case...more

Latham & Watkins LLP

Court of Appeal Excuses Non-Payment Arising From Secondary Sanctions Concerns

Latham & Watkins LLP on

The Court of Appeal decision, which considered standard form wording and the “mandatory” nature of US sanctions laws, upholds a High Court ruling exempting a borrower’s non-payment of interest, albeit on different grounds. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2019

ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2018

ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more

Bass, Berry & Sims PLC

Rare Court Case Sheds Light on U.S. Sanctions Enforcement

Bass, Berry & Sims PLC on

It is rare for companies to go to court to fight penalties imposed by the Office of Foreign Assets Control (OFAC) for violations of U.S. sanctions. It is even more rare for a court to make any sort of finding against the...more

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