News & Analysis as of

Office of Foreign Assets Control (OFAC) Economic Sanctions Money Laundering

Troutman Pepper Locke

Crude Crimes: Treasury Warns on Oil Smuggling and Money Laundering

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The Treasury Department has taken initial steps to implement the Trump administration’s “total elimination” policy directed at certain drug trafficking cartels. Most recently, on May 1, Treasury’s Financial Crimes Enforcement...more

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

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

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As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

The Volkov Law Group

Family International and Owner Pay $1.07 Million to Settle Violations of Russia Sanctions Program

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Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with  OFAC for $1.07 million for 73 violations of the Russia Sanctions program.  In a separate criminal case, Roman Sinyavsky...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

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We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

BakerHostetler

Weekly Blockchain Blog - December 2024 #3

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Digital Asset Companies Achieve Licenses, Launch Stablecoin Products - According to a recent press release, Anchorage Digital, a digital asset platform and infrastructure provider, announced that the New York State...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

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

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In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado...more

Vinson & Elkins LLP

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

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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

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - March 2024

On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

Ballard Spahr LLP

All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury...

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Complex Civil and Criminal Cases Converge - On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more

Ankura

Preventing the Use of Cryptocurrencies to Evade Sanctions

Ankura on

Cryptocurrencies have been making the headlines for all the wrong reasons. Their values have plummeted leaving investors out of pocket. Exchanges, lenders, and other entities in the crypto ecosystem have gone bust. Numerous...more

Ballard Spahr LLP

DOJ Seeks to “KleptoCapture” Sanctioned Russian Oligarch’s NYC and Miami Properties Via Forfeiture

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Last month we blogged on an indictment in the Southern District of New York (“SDNY”) charging Vladimir Voronchenko (“Vorenchenko”) with scheming to make payments to maintain multiple properties in New York and Florida owned...more

Orrick, Herrington & Sutcliffe LLP

OFAC announces sanctions tied to Central America drug trafficking

On February 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13581, against an individual based in Honduras and another individual based in Nicaragua...more

Guidepost Solutions LLC

Focus on Foreign Banks’ Sanctions Compliance Programs in the U.S. and Globally - Upgrading and Empowering Compliance to Help...

As the Russia – Ukraine war rages on, one outcome so far is clear: the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against...more

Ballard Spahr LLP

Russian Agent’s Beverly Hills Condominiums Subject to Forfeiture Based on Alleged Violations of Bank Fraud, Money Laundering, and...

Ballard Spahr LLP on

Indictment Alleges Use of Shell Companies, Nominees, Foreign Bank Accounts and Real Estate - On December 7, 2022, the United States Attorney’s Office for the Eastern District of New York (“DOJ”) unsealed a seven-count...more

Ballard Spahr LLP

Kraken Settlement Demonstrates Importance of Sanctions Monitoring for Transactions — Not Just When Onboarding Customers

Ballard Spahr LLP on

The Office of Foreign Assets Control (“OFAC”) announced (here and here) yesterday that virtual currency exchange Payward, Inc. – better known as Kraken – has agreed to pay $362,158.70 in order to settle its potential civil...more

The Volkov Law Group

Bittrex’s Sanctions and AML Violations: The Importance of Compliance Controls for the Cryptocurrency Industry (Part II of II)

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In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets,...more

Wilson Sonsini Goodrich & Rosati

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

K2 Integrity

The North Korean Crypto Threat

K2 Integrity on

Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Lowenstein Sandler LLP

OFAC Designates Tornado Cash as a Sanctioned Entity as Federal Government Continues to Increase Regulation of Decentralized...

Lowenstein Sandler LLP on

On Aug. 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned cryptocurrency mixer Tornado Cash for allegedly helping launder more than $7 billion worth of cryptocurrency over three years.1...more

BakerHostetler

Developer Arrested Following OFAC Sanctions of the Tornado Cash Protocol

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Takeaways - ..The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the first-ever smart contracts sanction, and its decision to sanction a nonperson may be challenged in court. ..The U.S....more

Latham & Watkins LLP

OFAC Sanctions Decentralized Virtual Currency Mixer

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The US Treasury opens a Pandora’s box of legal issues as it targets a decentralized finance protocol used for both licit and illicit means. On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets...more

The Volkov Law Group

OFAC Settles for $430,500 with American Express National Bank for Violation of Foreign Narcotics Kingpin Sanctions

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Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front.  Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more

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