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On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more
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
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
Sanctions law can be complex. The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more. ...more