Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”)....more
Developments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the...more
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
12/6/2024
/ Blockchain ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Money Transmitter ,
Office of Foreign Assets Control (OFAC) ,
Open Source Software ,
SDN List ,
Smart Contracts ,
U.S. Treasury ,
Virtual Currency
As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more
11/27/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CFTC ,
Consent Order ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
FinCEN ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Plea Agreements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Suspicious Activity Reports (SARs)
The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more
11/17/2023
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Declaratory Judgments ,
Department of Justice (DOJ) ,
Due Process ,
Enforcement Actions ,
Federal Reserve ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
Preliminary Injunctions ,
Puerto Rico ,
Suspicious Activity Reports (SARs)
The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more