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Recent OFAC and DOJ Activity Signals Potential New Era of Control-Based Sanctions Enforcement

U.S. sanctions enforcement is evolving to adopt a “control” analysis similar to the analysis employed by the European Union and United Kingdom based on a recent major enforcement action by the U.S. Department of the...more

Cryptocurrency: Legal Developments and Outlook

Federal and state regulators have taken an increased interest in regulating cryptocurrencies, digital assets, and the larger blockchain ecosystem. This landscape is opaque and rapidly evolving, and many industry participants...more

Patchwork of Cryptocurrency Regulators Increasingly Stitch Together Cooperative Enforcement Efforts

Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks - Amid...more

Personal Liability Exposure for Bank Executives and Compliance Officers

On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more

e.l.f. Cosmetics Agrees to Pay Nearly $1 Million To Settle Apparent Violations Of U.S. Sanctions Against North Korea

This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence - On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more

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