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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

Hogan Lovells

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

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The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

Orrick, Herrington & Sutcliffe LLP

5th Circuit reverses and remands cryptocurrency software case stating OFAC exceeded its authority

On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...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

BakerHostetler

Crypto Firms Launch New Initiatives; Whitepapers Address DeFi, Crypto Risks, CBDCs; OFAC Adds Crypto Addresses to SDN List...

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Crypto Firms Continue to Launch New Initiatives Across Markets - In a recent press release, digital asset infrastructure firm Fireblocks announced its acquisition of BlockFold, “a smart contract development and...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

Civil Complaint Challenges OFAC’s Tornado Cash Sanctions

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Last month, the Office of Foreign Assets Control (“OFAC”) sanctioned Tornado Cash, a virtual currency “mixer” operating on the Ethereum blockchain which allegedly has been used to launder the virtual currency equivalent of...more

Husch Blackwell LLP

OFAC's Crackdown on Tornado Cash Protocol Raises Specter of Future Liability Concerns

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The Office of Foreign Assets Control (OFAC) recently made the unprecedented move of sanctioning a smart contract — a decentralized digital currency mixer called “Tornado Cash” — along with certain cryptocurrency addresses...more

Sheppard Mullin Richter & Hampton LLP

The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more

Skadden, Arps, Slate, Meagher & Flom LLP

NY Department of Financial Services Outlines How Blockchain Analytics Should Be Used for Compliance

On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more

Troutman Pepper Locke

New York Issues Guidance on Virtual Currency Regulations and Announces Strengthening Blockchain Analytics in Response to Sanctions...

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On February 25, the New York State Department of Financial Services (NYDFS) issued Guidance to all individuals and entities subject to its regulation due to the rapidly evolving situation in Ukraine, following the Russian...more

BakerHostetler

Crypto Payment Products Launch; SEC Addresses DeFi, Targets DAO Tokens; OFAC Adds Crypto Exchange to SDN List; Crypto Fraud...

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New Crypto Payment Products Launch, Report Cites Exchange Consolidation - This week, a major U.S. financial services firm announced its partnership with three leading cryptocurrency service providers in the Asia Pacific...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more

Foodman CPAs & Advisors

OFAC Puts Virtual Currency Industry on Notice

In a new Sanctions Compliance Guide, The Office of Foreign Assets Control (OFAC) of the U.S. Treasury reiterates that compliance obligations apply equally to transactions involving virtual currencies and those involving...more

Kramer Levin Naftalis & Frankel LLP

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...more

Latham & Watkins LLP

DOJ and Treasury Take Crypto Enforcement to the Next Level

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The DOJ’s National Cryptocurrency Enforcement Team and Treasury’s OFAC are setting their sights on cryptocurrency use in cybercrimes. The US Department of Justice (DOJ) is sharpening its focus on combatting...more

Cooley LLP

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC’s...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...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

WilmerHale

OFAC Imposes New Sanctions to Thwart Ransomware

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On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

Orrick - On the Chain

Cryptocurrency and OFAC: Beware of the Sanctions Risks

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A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more

King & Spalding

Virtual Currency in Sanctioned Jurisdictions

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Stepping outside of SWIFT - Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more

Dechert LLP

Crypto Never Sleeps: Vigilance Required in OFAC Sanctions Compliance Involving Virtual Currencies and Digital Assets

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For years, regulators around the world have struggled with whether and how to police the offering and exchange of digital assets (including virtual currencies such as Bitcoin). In the United States, such efforts were stymied...more

Kramer Levin Naftalis & Frankel LLP

OFAC Issues Cryptocurrency Compliance Guidance

As part of the ongoing efforts of the federal government, agencies and financial market regulators to respond to the growing cryptocurrency market, the Office of Foreign Asset Control (OFAC) of the Department of Treasury...more

Sheppard Mullin Richter & Hampton LLP

Digital Cops and Cyber Robbers: OFAC Guidance on Crypto Currency

A lot of us in the sanctions compliance world were wondering whether and when OFAC would issue official guidance on its application of sanctions in the digital currency world. On March 18, OFAC issued five FAQs related to...more

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