News & Analysis as of September 20, 2024

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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 -

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

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

Sheppard Mullin Richter & Hampton LLP on 12/4/2023

The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...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

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

Sheppard Mullin Richter & Hampton LLP on 11/27/2023

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

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on 11/14/2023

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...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 Require Recordkeeping and Reporting for CVC Mixing Transactions

Ballard Spahr LLP on 11/1/2023

On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

Eversheds Sutherland (US) LLP on 10/30/2023

On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...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 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

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

Kraken Settlement Demonstrates Importance of Sanctions Monitoring for Transactions — Not Just When Onboarding Customers

Ballard Spahr LLP on 11/30/2022

The Office of Foreign Assets Control (“OFAC”) announced (here and here) yesterday that virtual currency exchange Payward, Inc. – better known as Kraken – has agreed to pay $362,158.70 in order to settle its potential civil...more

Blockchain Game Developers and FinCEN: When are State Money Transmission Laws Applicable?

Sheppard Mullin Richter & Hampton LLP on 10/4/2022

The rising prevalence of crypto and virtual currencies has invited the scrutiny of several regulatory bodies who continue to grapple with the unique challenges posed by blockchain technology, FinCEN being one prime example....more

OFAC Sanctions Virtual Currency “Mixer” Tornado Cash and Faces Crypto Backlash

Ballard Spahr LLP on 8/25/2022

On August 8, the U.S. Department of the Office of Foreign Assets Control (“OFAC”) sanctioned “notorious” virtual currency “mixer” Tornado Cash, which allegedly has been used to launder more than $7 billion worth of virtual...more

Sanctions Against Russia: The Week in Review - April 2022 - 3

K2 Integrity on 4/27/2022

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

OFAC Designates “Hydra” – the Largest Darknet Market – and Third Russian Virtual Currency Exchange

Ballard Spahr LLP on 4/7/2022

On April 5, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against “the world’s largest and most prominent darknet market, Hydra Market” and Garantex, a virtual...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

The Extension of FAFT’s ‘travel Rule’ and Implications for Virtual Asset Service Providers in the UK

McDermott Will & Emery on 2/25/2022

The extension of the Financial Action Task Force (FATF) ‘Travel Rule’ to ‘Virtual Asset Service Providers’ (VAPSs) is emblematic of the continued and growing push to bring crypto businesses into the mainstream of financial...more

A Record $3.6 Billion Seizure and the Twisting Paths of Money Laundering in the Digital World

Ballard Spahr LLP on 2/14/2022

On February 8, 2022, the Department of Justice announced the seizure of a record $3.6 billion in stolen BTC it alleges was tied to the 2016 hack of Bitfinex, a virtual currency exchange. A husband-wife duo, Ilya “Dutch”...more

FinCEN Crypto & Ransomware Guidance: Will 2022 Bring More Changes?

Torres Trade Law, PLLC on 1/26/2022

The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...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

FinCEN Reports Spiraling SARs Relating to Ransomware

Ballard Spahr LLP on 10/22/2021

On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...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

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Virtual Currency › Money Laundering › FinCEN

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