News & Analysis as of September 19, 2024

U.S. Treasury

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

Weekly Blockchain Blog - August 2024 #4

BakerHostetler on 8/26/2024

Financial Firms Announce Crypto Initiatives, Stablecoin Growth Continues - A major U.S. crypto investment company recently announced the launch of its Avalanche Trust, which “offers investors the opportunity to gain...more

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - December 2023

Lowenstein Sandler LLP on 12/11/2023

TRADE TIP OF THE MONTH: New Companies Have More Time To Report Ownership- The Treasury Department’s Financial Crimes Enforcement Network issued a final rule in late November to delay the deadline for newly created...more

Hamas, Terrorist Financing, and Cryptocurrency

Ballard Spahr LLP on 12/8/2023

The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more

FinCEN to Shed Light on Illicit Use of Virtual Currency Mixing Through Enhanced Record Keeping and Reporting Requirements

Troutman Pepper on 11/29/2023

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) that identifies international convertible virtual currency mixing as a class of...more

Treasury Department Announces Largest Settlement in History and Severe Penalties Against Binance

Kelley Drye & Warren LLP on 11/27/2023

On November 21, 2023, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), announced unprecedented actions against Binance Holdings Ltd. (Binance) and...more

FinCEN Releases Proposed Rule Designating CVC Mixing as a “Primary Money Laundering Concern”

Wilson Sonsini Goodrich & Rosati on 11/8/2023

On October 23, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (proposed rule) addressing “mixing transactions” that involve convertible...more

FinCEN Proposes To Designate Convertible Virtual Currency Mixing as a Primary Money Laundering Concern

Skadden, Arps, Slate, Meagher & Flom LLP on 10/27/2023

The Proposed Rule Aims To Increase Transparency in CVC Mixing - On October 19, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a notice of proposed rulemaking (Proposal)...more

FinCEN Targets Convertible Virtual Currency Mixing to Combat Terrorist Financing and Other Illegal Transactions

Morrison & Foerster LLP on 10/27/2023

Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more

FinCEN Issues Alert for Financial Institutions on Red Flags for “Pig Butchering” Schemes

Troutman Pepper on 9/13/2023

On September 8, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) issued an alert warning financial institutions to be vigilant against a prominent virtual currency investment scam called...more

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

Ballard Spahr LLP on 8/30/2023

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

Daily Financial Regulation Update -- Monday, April 24, 2023

Paul Hastings LLP on 4/24/2023

April 21, 2023- Assistant Secretary of the Treasury for Terrorist Financing and Financial Crimes Elizabeth Rosenberg and Deputy Homeland Security Adviser Joshua Geltzer hosted a roundtable at the U.S. Department of the...more

In the First Use of Its Section 9714 Powers, the U.S. Treasury Designated Bitzlato as a Russian-Linked Primary Money Laundering...

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2023

On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more

FinCEN prohibits engagement with virtual currency exchange connected to Russian finance

Orrick, Herrington & Sutcliffe LLP on 1/20/2023

On January 18, the Financial Crimes Enforcement Network (FinCEN) issued its first order pursuant to section 9714(a) of the Combating Russian Money Laundering Act to identify a Hong Kong-registered global virtual currency...more

Daily Financial Regulation Update -- Thursday, January 19, 2023

Paul Hastings LLP on 1/20/2023

January 18, 2023- The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued an order that identifies the virtual currency exchange Bitzlato Limited (Bitzlato) as a "primary money laundering...more

Sanctions Against Russia: The Week in Review - March 2022

K2 Integrity on 3/18/2022

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on 3/14/2022

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on 11/11/2021

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

Trade Matters - November 2021

Lowenstein Sandler LLP on 11/3/2021

1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more

Sanctions 2.0: US Treasury Department announces results of sanctions policy review and OFAC releases compliance guidance for the...

Eversheds Sutherland (US) LLP on 10/29/2021

The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on 10/26/2021

Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on 10/25/2021

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

National Cryptocurrency Enforcement Team Turns Up the Crypto Heat

Wilson Sonsini Goodrich & Rosati on 10/19/2021

Earlier this month, the U.S. Department of Justice (DOJ) announced the creation of a National Cryptocurrency Enforcement Team (NCET) to "tackle complex investigations and prosecutions of criminal misuses of cryptocurrency,...more

OFAC Imposes New Sanctions to Thwart Ransomware

WilmerHale on 9/24/2021

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

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on 7/7/2021

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

As Treasury Eyes Crypto in Tax Compliance Agenda, Reporting Obligations May Increase – Including a Crypto “Form 8300” for...

Ballard Spahr LLP on 6/3/2021

Treasury Offers Something for Everyone to Comply With: Trades and Businesses, Banks, Crypto Exchangers and Individuals - On May 21, 2021, the U.S. Department of Treasury (“Treasury”) released its American Families Plan Tax...more

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