News & Analysis as of

Cryptocurrency U.S. Treasury Economic Sanctions

Paul Hastings LLP

A Whirlwind of Change: The Delisting of Tornado Cash

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Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

K2 Integrity on

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

BCLP

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

BCLP on

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

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

Ballard Spahr LLP on

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

Vinson & Elkins LLP on

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

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You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

K2 Integrity

U.S. Authorities Amplify Enforcement Efforts to Address Financial Crime Risks in the Digital Asset Industry

K2 Integrity on

The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...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

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

Lowenstein Sandler LLP

OFAC Designates Tornado Cash as a Sanctioned Entity as Federal Government Continues to Increase Regulation of Decentralized...

Lowenstein Sandler LLP on

On Aug. 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned cryptocurrency mixer Tornado Cash for allegedly helping launder more than $7 billion worth of cryptocurrency over three years.1...more

BakerHostetler

Developer Arrested Following OFAC Sanctions of the Tornado Cash Protocol

BakerHostetler on

Takeaways - ..The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the first-ever smart contracts sanction, and its decision to sanction a nonperson may be challenged in court. ..The U.S....more

Latham & Watkins LLP

OFAC Sanctions Decentralized Virtual Currency Mixer

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The US Treasury opens a Pandora’s box of legal issues as it targets a decentralized finance protocol used for both licit and illicit means. On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets...more

Sheppard Mullin Richter & Hampton LLP

The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and...more

Lowenstein Sandler LLP

Trade Matters, April 2022: A monthly newsletter covering global trade & national security developments

Lowenstein Sandler LLP on

1. Updates to Russia Sanctions and Export Controls- In response to the ongoing attack on Ukraine, the U.S. government continues on a weekly basis to increase economic sanctions and export controls on Russia. ...more

White & Case LLP

US Regulators Seek to Prevent Use of Crypto to Circumvent Russia Sanctions

White & Case LLP on

Cryptocurrency's reputation for enabling transactions outside of the traditional financial ecosystem has prompted concerns that it may serve as a tool for Russian actors to evade recently promulgated sanctions against the...more

K2 Integrity

Sanctions Against Russia: The Week in Review - March 2022 - 2

K2 Integrity on

The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...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

Bracewell LLP

KYC in a Digital World, How New Sanctions and AML Expectations Have Upped the Stakes and What you Need to Do About it

Bracewell LLP on

“Know your customer” is a bed rock principle of anti-money laundering and sanctions compliance programs, but it’s not always easy, particularly as more sophisticated and aggressive players have taken the field in recent...more

BCLP

Cryptocurrency as Sanctions Circumvention: Crisis? Canard? TBD?

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Much has been written and spoken in the past weeks about Russia’s potentially using cryptocurrency to evade the raft of international sanctions imposed on the country due to its ongoing actions in Ukraine. U.S. Department of...more

Troutman Pepper Locke

US Announces Crypto-Specific Guidance on Avoidance of Russian Sanctions

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On March 11, Britain, Canada, France, Germany, Italy, Japan, and the United States (collectively, the G7) announced more sanctions against Russia, including first-time sanctions specific to virtual assets. The White House...more

Wiley Rein LLP

U.S. Moves to Regulate Digital Currencies More Closely: Strongly Considers Establishing a U.S. Central Bank Digital Currency

Wiley Rein LLP on

What: On March 9, 2022 President Biden signed an Executive Order (EO) on digital assets, including cryptocurrencies, and the possible creation of Central Bank Digital Currencies (CBDC) for a digital form of the country’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more

Latham & Watkins LLP

DOJ and Treasury Take Crypto Enforcement to the Next Level

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The DOJ’s National Cryptocurrency Enforcement Team and Treasury’s OFAC are setting their sights on cryptocurrency use in cybercrimes. The US Department of Justice (DOJ) is sharpening its focus on combatting...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

Kelley Drye & Warren LLP

Treasury Announces A More Tailored Approach to U.S. Sanctions Policy

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Yesterday, the Biden Administration released the results of a broad review of U.S. economic sanctions policy following two decades of expanding use of sanctions as a foreign policy tool. The report recognizes that U.S....more

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