News & Analysis as of

Cryptocurrency Office of Foreign Assets Control (OFAC) Bank Secrecy Act

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

Latham & Watkins LLP on

Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

The Volkov Law Group

Episode 302 -- Matt Stankiewicz on DOJ's Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng...

The Volkov Law Group on

On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Ballard Spahr LLP

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

Ballard Spahr LLP on

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

Oberheiden P.C.

National Security in the Age of Blockchain

Oberheiden P.C. on

Blockchain presents unprecedented challenges around national security. This is true not only for the federal government, but also for businesses in the private sector. From cross-border transactions involving cryptocurrency...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”

Ballard Spahr LLP on

The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more

Harris Beach Murtha PLLC

Potential BSA/AML Roadmap – Crypto Exchange Bittrex Enforcement Actions

Harris Beach Murtha PLLC on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) settled enforcement actions with Washington state-based Bittrex. In the two settlements, Bittrex...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

McGlinchey Stafford

FinCEN and OFAC Issue First Joint Action in Cryptocurrency Market

McGlinchey Stafford on

On October 11, 2022, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) acted in parallel to issue the first joint action in the cryptocurrency market against Bittrex. Bittrex...more

BakerHostetler

Major U.S. Crypto Exchange Consents to $29 Million Penalty for Historic BSA and OFAC Violations

BakerHostetler on

​​​​​​​On October 11, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced a $29 million civil monetary penalty against Bittrex, a...more

Ballard Spahr LLP

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

Ballard Spahr LLP on

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

Venable LLP

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

Venable LLP on

​​​​​​​The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

BakerHostetler

Applying the Bank Secrecy Act, FinCEN Regulations, and Sanctions to the Nascent NFT Market

BakerHostetler on

Non-fungible tokens (NFTs) often involve two areas with known money laundering and terrorist financing risks: cryptocurrencies and high-value assets, like art. As detailed below, the U.S. Treasury Department’s Financial...more

Ballard Spahr LLP

Russian Sanctions: FinCEN Provides Red Flags for Potential Evasion Attempts

Ballard Spahr LLP on

On March 7, the Financial Crimes Enforcement Network (FinCEN) issued an alert “advising all financial institutions to be vigilant against potential efforts to evade the expansive sanctions and other U.S.-imposed restrictions...more

Perkins Coie

Recent Developments in US Sanctions and Export Controls Targeting Russia

Perkins Coie on

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

Orrick, Herrington & Sutcliffe LLP

Non-U.S. Crypto and Other Money Services Businesses: Have Customers in the U.S.? Beware of AML and Sanctions Compliance Risks

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

Orrick - On the Chain

Non-U.S. Crypto and Other Money Services Businesses: Have Customers in the U.S.? Beware of AML and Sanctions Compliance Risk

Orrick - On the Chain on

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

Skadden, Arps, Slate, Meagher & Flom LLP

Cryptocurrency Regulation and Enforcement at the US Federal and State Levels

In recent months, the increased focus on cryptocurrency regulation and enforcement at both the federal and state levels demonstrates the digital currency’s place as an established component of the financial landscape. At the...more

McGlinchey Stafford

Scared Of Your Clients’ Involvement With Cryptocurrency?

McGlinchey Stafford on

Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Are Nonfungible Tokens Subject to US Anti-Money Laundering Requirements?

Rapidly growing interest in nonfungible tokens (NFTs) has been fueled by recent headlines of multimillion-dollar transactions, such as the $69 million sale of an NFT by digital artist Beeple — the third-highest price ever...more

Kelley Drye & Warren LLP

DOJ Activity on Cryptocurrency: A Six-Month Review

The U.S. Department of Justice (“DOJ”) has focused on cryptocurrency in the last six months, while consumer interest hits all-time highs. The cryptocurrency market is not unlike the cannabis market from several years...more

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