News & Analysis as of

Sanctions FinCEN

Ballard Spahr LLP

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

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On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more

Mayer Brown

The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

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On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

Cadwalader, Wickersham & Taft LLP

FFFrictions, August 2025 - FinCEN Restrictions on Certain Mexican Banks

New and significant prohibitions against financial transactions between U.S. financial institutions and three Mexican financial institutions are set to go into effect in a little over a month on September 4, 2025. In late...more

K2 Integrity

Risks Increase As U.S. Escalates Pressure Against Mexico With Regulatory Focus On The Financing Of Fentanyl

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The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more

Mayer Brown

FinCEN's First Strike: New Section 311 Powers Target Mexican Financial Institutions Under FEND Off Fentanyl Act

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In this episode, host Lauren Pryor and her colleagues discuss the recent actions by FinCEN, which designated three Mexican financial institutions as primary money laundering concerns under the expanded Section 311 authority,...more

K2 Integrity

The United States Terminates Countrywide Syria Sanctions and Is Working Towards Lifting Additional Trade Restrictions

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Building on prior relief of sanctions and other restrictive trade measures earlier this year (as described in K2 Integrity alerts dated 15 May and 09 June 2025), on 30 June 2025, U.S. President Donald Trump issued a new...more

Bradley Arant Boult Cummings LLP

How the Trump Administration’s War on Cartels Will Reshape the Financial Sector

On March 11, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) aimed at disrupting drug trafficking and money laundering along the southwestern border. The...more

Foley Hoag LLP - White Collar Law &...

A Preview of SEC, CFTC, AML, Sanctions and CFIUS Enforcement Priorities Under the Second Trump Administration

As the incoming Trump administration prepares to take office, businesses and investors can expect significant shifts in the enforcement priorities of the Securities and Exchange Commission (SEC) and the Commodity Futures...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act - Overview of Filing Requirements

Background - The Corporate Transparency Act of 2019 (“CTA”) became effective on January 1, 2024. Under the CTA, all “reporting companies” must file a Beneficial Ownership Information (BOI) report with the Financial Crimes...more

Guidepost Solutions LLC

Crypto Crackdown: 8 Key BSA/AML Fundamentals for FinTechs

In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Bass, Berry & Sims PLC

Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations

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On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had...more

Sheppard Mullin Richter & Hampton LLP

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

American Conference Institute (ACI)

[Event] 2nd Forum on Digital Assets Compliance: AML, Sanctions and Regulatory Oversight - October 17th - 18th, New York, NY

With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

K2 Integrity

FINCast Ep. 36 – Regulators’ Roundtable to Forecast 2023

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On FINCast Episode 36, Juan Zarate hosts a roundtable discussion with K2 Integrity’s Mariano Federici, Bryan Stirewalt, and Emma Walker to discuss what they are watching for 2023 in the financial crime and sanctions...more

Wilson Sonsini Goodrich & Rosati

Cryptocurrency Exchange Platform Agrees to Pay over $53 Million for Anti-Money Laundering and Sanctions Violations

On October 11, 2022, the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced settlements with Bittrex Inc. (Bittrex). The settlements arise from violations of...more

Holland & Hart LLP

Goodbye Shareholder Anonymity, Hello Transparency

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Throughout US history, most businesses have been able to organize and operate without needing to disclose their ownership or management. This privacy afforded to businesses and their management, along with the protection of...more

Morrison & Foerster LLP

U.S. Government Takes Increasingly Aggressive Actions Targeting Ransomware

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On November 8, 2021, the U.S. Department of Justice (“DOJ”), U.S. Department of the Treasury (“Treasury”), and the U.S. Department of State (“State”) made several significant announcements regarding recent U.S. government...more

Lowenstein Sandler LLP

Trade Matters - November 2021

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1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Department of the Treasury Publishes Sanctions Review Results

On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

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Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

Adams & Reese

The Department of Treasury Issues Guidance Regarding Sanctions Risks Inherent to Facilitating Ransomware Payments

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On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more

Baker Donelson

New Ransomware Advisories from OFAC and FinCEN Create Additional Challenges for Financial Institutions

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Both the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury have issued advisories recently regarding regulatory considerations financial...more

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