Following an earlier announcement on July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), on August 5, 2025, issued an Exemptive Relief Order (“Order”) to delay for two years,...more
June marked a pivotal moment in U.S. digital asset oversight with major developments from the SEC, Congress, and the DOJ. First, on June 9, 2025, the SEC’s Crypto Task Force held its final scheduled roundtable called “DeFi...more
In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more
In May 2025, the leadership from the SEC provided guidance on digital asset regulation in several keynote addresses and round tables. The SEC's activities in May 2025 suggest a deliberate movement towards establishing a more...more
In March 2024, NSD issued an updated Enforcement Policy for Business Organizations (NSD Enforcement Policy) that includes the M&A Policy. Under the M&A Policy, where an acquiring company makes a qualifying voluntary...more
Following a two-week Easter recess at the end of April, Congress returned to Washington, D.C. with all eyes on budget reconciliation. Individual committees marked up legislation in accordance with reconciliation directives to...more
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with President Trump’s May 13, 2025...more
CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more
Both the CFTC and SEC have new Acting Chairs, who are known to be crypto advocates, with Mark Uyeda being appointed Acting Chair of the SEC, taking over from Gary Gensler, while Caroline D. Pham has assumed the role of Acting...more
2/12/2025
/ Administrative Appointments ,
Bitcoin ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Financial Regulatory Reform ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Trump Administration
CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more
1/14/2025
/ Artificial Intelligence ,
Bitcoin ,
Blockchain ,
CFTC ,
Crypto Exchanges ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Financial Conduct Authority (FCA) ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Fraud ,
Investment ,
NVIDIA ,
Regulation S-K ,
Regulatory Agenda ,
Russia ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
UK
CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more
12/19/2024
/ Bitcoin ,
Blockchain ,
CFTC ,
Cryptoassets ,
Cryptocurrency ,
Cyber Crimes ,
Due Diligence ,
Enforcement ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Investment ,
Misleading Statements ,
Money Laundering ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Phishing Scams ,
Proposed Regulation ,
Reporting Requirements ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Sentencing ,
Smart Contracts ,
Tokenization ,
UK
Key Points - On May 10, 2024, OFAC issued an IFR that would amend its Reporting, Procedures and Penalties Regulations (RPPR) at 31 C.F.R. Part 501 to, among other things, modify certain reporting requirements pertaining to...more
In February 2024, the U.S. Department of the Treasury issued its 2024 Investment Adviser Risk Assessment, which explains that there are “several illicit finance threats involving investment advisers,” including that...more
5/17/2024
/ AML/CFT ,
Customer Identification Program (CIP) ,
Exempt Reporting Advisers (ERAs) ,
FinCEN ,
Investment Adviser ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Venture Capital
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
5/1/2024
/ Department of Justice (DOJ) ,
Drug Trafficking ,
Economic Sanctions ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
New Legislation ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Sanction Violations ,
Statute of Limitations ,
TWEA
Key Points - On April 17, 2024, based on a determination by the U.S. government that Nicolás Maduro and his representatives “have not fully met the commitments made” with respect to upcoming Venezuelan elections, the U.S....more
A U.S. District Court judge in Alabama recently ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA, which was enacted on January 1, 2021, directs the U.S. Department of the Treasury’s Financial...more
Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more
2/16/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Chief Compliance Officers ,
Due Diligence ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Investors ,
Notice of Proposed Rulemaking (NOPR) ,
Policies and Procedures ,
Proposed Rules ,
Recordkeeping Requirements ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
Key Points - On January 31, 2024, the Department of Defense (DoD) released an update to its list of “Chinese military companies” that are “operating directly or indirectly in the United States” in accordance with the...more
2/7/2024
/ Bureau of Industry and Security (BIS) ,
China ,
Department of Defense (DOD) ,
Executive Branch ,
Military Contracts ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Proposed Legislation ,
Regulatory Requirements ,
SDN List ,
Trade Restrictions
Key Points -
On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more
1/19/2024
/ CAPTA List ,
Certification Requirements ,
Criminal Prosecution ,
Customs and Border Protection ,
Due Diligence ,
Economic Sanctions ,
Executive Orders ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Forfeiture ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Prohibited Transactions ,
Russia ,
SDN List ,
Supply Chain
In the two weeks since the Corporate Transparency Act (CTA) went into effect (see our alert here), the Financial Crimes Enforcement Network (FinCEN) has published several Frequently Asked Questions (FAQs) clarifying the new...more
1/17/2024
/ Beneficial Owner ,
Beneficiaries ,
Corporate Entities ,
Corporate Transparency Act ,
Exemptions ,
FinCEN ,
Grantors ,
Intermediaries ,
Joint Ownership ,
New Guidance ,
Reporting Requirements ,
Smaller Reporting Companies ,
Subsidiaries ,
Tax Exempt Entities ,
Trustees
Key Points -
The Corporate Transparency Act (the “CTA”), implemented primarily through a rule published by FinCEN on September 30, 2022, the Beneficial Ownership Information Reporting Rule (“BOIR Rule”), becomes effective...more
Key Points -
On October 18, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took action to relax certain U.S. sanctions on Venezuela in response to the signing of an electoral roadmap...more
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
8/7/2023
/ Anti-Corruption ,
Bureau of Industry and Security (BIS) ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Controls ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury ,
Voluntary Disclosure
Key Points -
The U.S. Department of Commerce has reorganized and clarified the regulations describing when foreign-produced items outside the United States are and are not subject to the licensing and other obligations of...more
Key Points -
The United States, European Union, United Kingdom and other U.S. allies are currently considering a range of severe economic measures against Russia to impose in the event of a Russian military incursion into...more
1/31/2022
/ Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
Sanctions ,
SDN List ,
Ukraine