News & Analysis as of

Office of Foreign Assets Control (OFAC) Virtual Currency Enforcement Actions

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

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - December 2023 Updates

On the one hand, the year ended where it began. The legislation on stabelecoins and market structure that would provide a regulatory framework for digital assets has still not been enacted into law. And Securities and...more

Sheppard Mullin Richter & Hampton LLP

Sanctions Enforcement in the Cryptocurrency Industry Continues to be a Focus

On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...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

Morrison & Foerster LLP

OFAC Year in Review 2022 – Part 1

2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more

BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

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On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

The Volkov Law Group

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

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Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Holland & Knight LLP

Crypto Company Comes Under OFAC Scrutiny

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 11, 2022, announced a more than $24.28 million settlement with Bittrex Inc. (Bittrex), a Bellevue, Washington-based company that offers...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

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The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

Perkins Coie

OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

Perkins Coie on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more

BakerHostetler

Crypto Products Launch, Gain Approvals; OFAC Sanctions Crypto Mixer; SEC Publishes ICO Consent Order; Report Cites Criminal Use of...

BakerHostetler on

NY DFS Approves Crypto Platform, Prepaid Crypto Card to Launch in Argentina - According to a press release this week, the New York State Department of Financial Services (NY DFS) has authorized two subsidiaries of Zero...more

The Volkov Law Group

OFAC Focuses on Cybercrime by Sanctioning the Hydra Darknet Market and GARANTEX Cryptocurrency Exchange

The Volkov Law Group on

Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria.  On April...more

McDermott Will & Emery

[Webinar] Demystifying Cryptocurrency Law & Compliance - January 12th, 12:00 pm - 1:00 pm EST

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The cryptocurrency legal and compliance landscape is constantly changing, and there’s more scrutiny than ever before on the industry. Please join leading experts from McDermott Will & Emery and Bates Group for a discussion on...more

Bracewell LLP

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

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In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

Morrison & Foerster LLP

DOJ Announces Renewed Focus on Export Control and Sanctions Enforcement

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In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...more

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

Perkins Coie

OFAC Issues Second Ransomware Advisory and Designates Virtual Currency Exchange for Sanctions

Perkins Coie on

Agency’s Focus on Cryptocurrency and Blockchain Continues - On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more

Eversheds Sutherland (US) LLP

OFAC sanctions virtual currency exchange and updates ransomware advisory

On September 21, 2021, the US Department of the Treasury took actions in response to the increasing prevalence and severity of ransomware attacks in the United States and address the central role that virtual currency and...more

Fenwick & West LLP

OFAC Helps Those Who Help Themselves: How a Ransomware Response Plan Can Help Avoid Sanctions Enforcement for Ransom Payments

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Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more

BakerHostetler

Crypto Investment and Payment Products Launch, BiTA Platform Announced, SEC and OFAC Take Crypto Enforcement Actions, FCA Extends...

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Crypto Investment and Payments Products Launch, Payment Data Published - Last week Securitize announced the launch of Securitize Capital, which will serve as an investment manager of digital asset funds for institutional and...more

K2 Integrity

Virtual Assets and Sanctions: What Businesses Need to Know

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As virtual assets explode in value, use, and popularity, governments around the world are taking notice, increasing sanctions-related scrutiny of companies that provide related services and focusing regulatory and enforcement...more

Pillsbury - Global Trade & Sanctions Law

BitPay Inc. Enforcement Action Highlights Sanctions Compliance Risks for Virtual Currency Service Providers

On February 18, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) entered into a settlement of $507,375 with BitPay, Inc. (BitPay) for violations of multiple U.S. sanctions programs. According to...more

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