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Navigating FinCEN’s Actions on Huione Group: Strengthening Defenses Against Money Laundering

On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...more

A New Era for Digital Assets: The Impact of DOJ’s Shift Away from Regulation by Prosecution and Its Implications

In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital...more

Anti-Money Laundering Aspects of the GENIUS Act

On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

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

Blockchain Analysis and Related Expert Testimony Admissible In Criminal Trial

It is challenging for law enforcement to track down and trace illicit activities conducted through digital currencies. The process can be very time- and resource-intensive. Further, securing charges and arrests, and...more

Darkweb Cryptocurrency Mixer ChipMixer Shut Down for Allegedly Laundering $3 Billion Worth of Crypto

The U.S. Department of Justice (“DOJ”) announced on March 15, 2023 that in a coordinated effort between U.S. Federal Bureau of Investigations, Europol, and German police, the darknet cryptocurrency mixing service ChipMixer...more

Coinbase Settles with NYDFS for $100 Million Over Lax AML Safeguards

On January 4, 2023, the New York State Department of Financial Services (“NYDFS”) issued a consent order against Coinbase, Inc. (“Coinbase” or the “Company”), the largest U.S.-based cryptocurrency trading exchange, for...more

FinCEN Reports Spiraling SARs Relating to Ransomware

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 and CFTC Reach Groundbreaking $100 Million AML Settlement with BitMEX

Government Alleges Systemic and Deliberate AML Failures - Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring - The Financial Crimes Enforcement Network (“FinCEN”) and...more

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