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Cryptocurrency Economic Sanctions International Emergency Economic Powers Act (IEEPA)

Braumiller Law Group, PLLC

Braumiller Law Group - June 2025 Newsletter

A Q&A with Adrienne Braumiller, and Olivia Van Pelt. Question 1: How are you advising businesses in your jurisdiction when protecting themselves from the impact of trade wars and sanctions, and what strategies can...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

Troutman Pepper Locke

Tornado Cash Whiplash – What’s Next for Sanctions?

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We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more

BCLP

Fifth Circuit Rules OFAC Cannot Sanction Tornado Cash: Loper Bright Hamstrings OFAC’s Campaign Against Crypto Laundering

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Shortly before Thanksgiving, a panel of the United States Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) did not have the authority to sanction Tornado Cash, which offers a...more

Bracewell LLP

An "Immutable" Force Meets an Immovable Object: OFAC's Crypto Loss at the Fifth Circuit

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On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more

Hogan Lovells

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

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The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

Mayer Brown

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

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On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

Orrick, Herrington & Sutcliffe LLP

5th Circuit reverses and remands cryptocurrency software case stating OFAC exceeded its authority

On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

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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

Vinson & Elkins LLP

Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

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On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Morgan Lewis

Fifth Circuit Rejects OFAC’s Tornado Cash Sanctions

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In a ruling eagerly awaited by the cryptocurrency industry, the US Court of Appeals for the Fifth Circuit held that immutable smart contracts on the Tornado Cash crypto-transaction software protocol are not “property” subject...more

Seward & Kissel LLP

Changes Are Coming

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Elections, as they say, have consequences. That bit of political wisdom certainly will be true again this time around—our president-elect has been announcing appointees for cabinet positions that are bound to bring about...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

K2 Integrity

The North Korean Crypto Threat

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Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Mintz

DOJ issues charges in first criminal cryptocurrency sanctions case

Mintz on

Last Friday, a federal Magistrate Judge in Washington, D.C. wrote an opinion, in a still sealed case, explaining why he approved a DOJ criminal complaint against an American citizen accused of transmitting more than $10...more

Bracewell LLP

Sanctions and Cyber and Crypto, Oh My: The Convergence of Emerging Regulatory and Enforcement Risks Requires Nimble Responses...

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At a sanctions conference held in Washington D.C. on May 5, government officials, practitioners and corporations highlighted the government’s broadening focus on anti-corruption enforcement, across more traditionally siloed...more

King & Spalding

Virtual Currency in Sanctioned Jurisdictions

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Stepping outside of SWIFT - Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - March 2018

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

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