News & Analysis as of May 19, 2025

Economic Sanctions

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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 - December 2024 #3

BakerHostetler on 12/23/2024

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

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

Hogan Lovells on 12/16/2024

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

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

Orrick, Herrington & Sutcliffe LLP on 12/10/2024

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

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

Ballard Spahr LLP on 12/6/2024

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

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Morrison & Foerster LLP on 3/5/2024

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....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

Crypto Company Comes Under OFAC Scrutiny

Holland & Knight LLP on 10/25/2022

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

OFAC Announces Hefty Settlement with Virtual Currency Exchange / Hosted Wallet Services Provider

Sheppard Mullin Richter & Hampton LLP on 10/12/2022

Settlement Agreement with Bittrex, Inc. Today, on October 11, 2022, the Office of Foreign Assets Control (OFAC) announced a $24,280,829.20 settlement agreement with Bittrex, Inc., an online virtual currency exchange and...more

Civil Complaint Challenges OFAC’s Tornado Cash Sanctions

Ballard Spahr LLP on 9/16/2022

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

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

Sheppard Mullin Richter & Hampton LLP on 6/3/2022

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

U.S. Sanctions Transkapitalbank, Virtual Currency Mining Company, & Evasion Network

Kelley Drye & Warren LLP on 4/21/2022

Today, the U.S. Office of Foreign Assets Control (OFAC) designated Transkapitalbank, a privately-held Russian commercial bank, and its subsidiary, Investtradebank, as Specially Designated Nationals (SDNs). OFAC imposed...more

Update on OFAC Cyber Sanctions List: Hydra and Garantex

Robinson+Cole Data Privacy + Security Insider on 4/11/2022

On April 5, 2022, the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) sanctioned darkweb Hydra Marketplace and virtual currency Garantex and added both to the Specially Designated Nationals List (SDN). ...more

California DFPI Issues Guidance to Financial Institutions Regarding Russia Sanctions

Goodwin on 3/18/2022

On March 4, 2022, the California Department of Financial Protection and Innovation (DFPI) issued a reminder to its financial institution licensees regarding their obligations in light of the Russian invasion of Ukraine: ...more

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

Harris Beach Murtha PLLC on 3/15/2022

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

Global Markets May Face Risk of Virtual Currency Abuse as Russian Actors Seek to Circumvent Sanctions

K2 Integrity on 3/14/2022

The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...more

Economic Sanctions and Asset Seizures: An Important Focus for the Biden Administration

Proskauer - The Capital Commitment on 3/9/2022

Sanctions continue to be a dynamic area of regulation and enforcement. In its first year, the Biden Administration has already undertaken a number of different sanctions initiatives. The three examples below highlight the...more

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

Troutman Pepper Locke on 3/7/2022

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

Review of Sanctions and Export Control Developments in 2021 and What to Expect in 2022

Foley Hoag LLP - White Collar Law &... on 2/25/2022

This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...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

US Department of the Treasury Announces Results of Sanctions Review

Kramer Levin Naftalis & Frankel LLP on 11/11/2021

On Oct. 18, 2021, the U.S. Department of the Treasury (the Treasury) announced the results of its review of U.S. economic and financial sanctions. During her confirmation hearing in January 2021, Janet L. Yellen, secretary of...more

Ransomware and OFAC Sanctions Compliance

The Volkov Law Group on 11/4/2021

We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering...more

OFAC Puts Virtual Currency Industry on Notice

Foodman CPAs & Advisors on 11/2/2021

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

DOJ and Treasury Take Crypto Enforcement to the Next Level

Latham & Watkins LLP on 10/29/2021

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

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 Issues Sanctions Compliance Guidance for Virtual Currency Industry

Cooley LLP on 10/29/2021

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

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