The Department of Justice’s (DOJ) 90-day grace period for compliance with the Data Security Program (DSP) ends on July 8, 2025, and enforcement is expected to begin. This regulatory regime was created for national security...more
7/7/2025
/ China ,
Corporate Counsel ,
Covered Person ,
Cross-Border Transactions ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
Enforcement Actions ,
International Data Transfers ,
National Security ,
Regulatory Requirements
Orrick Partners Matthew Coleman and Jeanine McGuinness join RegFi co-hosts Jerry Buckley and Sherry Safchuk to explore the implications of the Justice Department’s recent issuance of a final rule prohibiting and restricting...more
On April 11, 2025, the Department of Justice’s (DOJ) National Security Division (NSD) released an Implementation and Enforcement Policy, a Compliance Guide, and a list of over 100 Frequently Asked Questions (FAQs) to help...more
On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more
The Department of Justice has finalized prohibitions and restrictions on cross-border transfers of certain data to China and other “Countries of Concern” (as defined below). It seeks to address what is, in the U.S....more
1/21/2025
/ Artificial Intelligence ,
China ,
Cuba ,
Data Privacy ,
Data Security ,
Department of Justice (DOJ) ,
International Data Transfers ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
National Security ,
Personal Data ,
Russia
On February 28, 2024, President Biden issued Executive Order 14117, calling for new regulations to prohibit or restrict transactions that enable countries of concern to access sensitive U.S. personal and government data. The...more
In light of Russia’s invasion of Ukraine and intensifying strategic competition with China, the U.S. government is prioritizing enforcement of export controls and economic sanctions in unprecedented ways. We expect higher...more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
3/4/2022
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BitMEX ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FinCEN ,
Guilty Pleas ,
Know Your Customers ,
Money Services Business ,
Office of Foreign Assets Control (OFAC)
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more
10/13/2021
/ Cryptocurrency ,
Cyber Attacks ,
Cybersecurity ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Risk Mitigation ,
Sanctions ,
SDN List ,
Virtual Currency
The Department of Justice (DOJ) announced last week and earlier this month civil forfeiture actions brought by the United States Attorney’s Office for the District of Columbia to seize stolen or laundered virtual currency...more
9/2/2020
/ Corruption ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Transactions ,
Forfeiture ,
Hackers ,
Money Laundering ,
Money Services Business ,
North Korea ,
Popular ,
Terrorist Financing Regulations ,
Virtual Currency ,
White Collar Crimes
On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more
12/23/2019
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
FCPA Corporate Enforcement Policy (CEP) ,
FCPA Guidance ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Sanction Violations ,
Self-Disclosure Requirements ,
Voluntary Disclosure