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SDN List Office of Foreign Assets Control (OFAC) Cryptocurrency

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

Troutman Pepper Locke on

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

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

Hogan Lovells

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

Hogan Lovells on

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

Latham & Watkins LLP

Fifth Circuit Overturns OFAC Sanctions Against Crypto Mixer Tornado Cash

Latham & Watkins LLP on

The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes....more

A&O Shearman

Fifth Circuit Limits OFAC Authority Over Certain Cryptocurrency Products

A&O Shearman on

On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s...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

Constangy, Brooks, Smith & Prophete, LLP

You’ve been hit with ransomware. Think twice before you pay.

You've been hit by a ransomware attack, and a cybercriminal group is demanding a cryptocurrency payment in exchange for your data's safe return. Should you pay? Deciding whether to pay a ransom is an internal business...more

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

BakerHostetler

Weekly Blockchain Blog - December 2024

BakerHostetler on

New Crypto Products Announced by Financial Services Firms, Exchanges, DEXs - A major U.S. cryptocurrency exchange recently announced that it has integrated a major mobile payments application into its Onramp tool to enable...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

Ballard Spahr LLP on

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

Victory for Tornado Cash as Court Rules Sanctions Were Unlawful

BakerHostetler on

On November 26, 2024, in a three-judge panel decision, Van Loon v. U.S. Department of the Treasury, the United States Court of Appeals for the Fifth Circuit (Court) reversed a Texas district court and held that immutable...more

BakerHostetler

Weekly Blockchain Blog - February 2024 #2

BakerHostetler on

U.S. Companies Announce Crypto Cashback and NFT Ticketing Initiatives - According to recent reports, a major U.S. credit card company has partnered with Swoo, a mobile wallet blending traditional and crypto payments, to...more

BakerHostetler

Crypto Products Launch; Bitcoin Ordinals Project Sells Out; U.S. EIA to Survey Miners; OFAC and DOJ Announce Crypto Actions;...

BakerHostetler on

New Crypto Indices Launch; Crypto Firms Announce Product Integrations - According to a recent press release, SIX, a major Swiss stock exchange and global financial information provider, has launched new SIX Reference Rate...more

BakerHostetler

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

BakerHostetler on

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

Patton Sullivan Brodehl LLP

The “DAO Jungle” Chronicles: Federal Judge Upholds Treasury Department’s Sanction of Tornado Cash for Involvement in Laundering...

In two prior posts, this blog tracked the ongoing intrigue of how the various branches of the United States government interact with blockchain and cryptocurrency organizations. We discussed the Wyoming law allowing...more

Dechert LLP

Tornado Watch: Popular Cryptocurrency Mixer “Tornado Cash” Dealt Two Major Blows in a Week

Dechert LLP on

Tornado Cash, a cryptocurrency mixer, recently suffered two major setbacks in federal regulatory efforts to block its use and prosecute its founders. First, a federal district court threw out a lawsuit challenging the...more

BakerHostetler

NFT Used for Service of Process; Blockchain CO2 Monitoring Solution Launches; IRS Addresses Staking; SEC Enforcement Continues;...

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Federal District Court Enters Default Judgment Based on NFT Service of Process - A federal district court judge in Florida entered a $2.2 million default judgment against a defendant on whom the judge previously authorized...more

BakerHostetler

Fintech Firms Launch New Products; Crypto Guidance Published by CFTC, EBA, UAE; OFAC Adds Public Keys to SDN List; CFTC, NY AG...

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Crypto Firms Announce New Product Launches in Custody, Stablecoins, Wallets - According to a recent press release, Prometheum Capital has received the first-ever approval from the Financial Industry Regulation Authority...more

BakerHostetler

ETH Staking Data Published; USDC Transfer Protocol Launches; OFAC Adds Public Keys to SDN List; DOJ Targets Crypto Market...

BakerHostetler on

ETH Staking Data Published, USDC Cross-Chain Transfer Protocol Launches - New data reflects that the recent amount of staking withdrawals on Ethereum has been balanced by a roughly equal amount of deposits. According to...more

Dorsey & Whitney LLP

U.S. Treasury Department Takes Action Against Russian Darkmarket Entity as Latest Government Move Against Cybercrime

Dorsey & Whitney LLP on

On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...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

BakerHostetler

White House Issues Statement on Crypto; Bitcoin ETF Rejected; OFAC Sanctions Public Keys; Regulators Address Digital Assets;...

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White House Addresses Crypto Risks; Blockchain Firm Wins Air Force Contract - The White House issued a statement last week briefly outlining the Biden administration’s road map to mitigate the risks of cryptocurrencies,...more

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