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Foley & Lardner LLP

FinCEN Exercises New Authority Targeting Mexico-Based Financial Institutions to Counter Cartel-Linked Fentanyl Trade

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On June 25, 2025, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury designated three Mexico-based financial institutions as primary money laundering concerns under Section 311 of the USA...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

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

Hogan Lovells on

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...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

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

Latham & Watkins LLP on

The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Troutman Pepper Locke

Sanctions Round-up and Possible New Russia Sanctions Triggered by Hostilities Against Ukraine

Troutman Pepper Locke on

The United States, primarily through Presidential action under the statutory authority of the International Emergency Economic Powers Act (“IEEPA”), has empowered the U.S. Department of the Treasury and its Office of Foreign...more

Orrick, Herrington & Sutcliffe LLP

Treasury Actions to Counter Ransomware

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more

Morgan Lewis

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more

Williams Mullen

Understanding the OFAC Sanctions Laws: Requirements for U.S. Companies

Williams Mullen on

It seems almost every day there are reports of new developments under the U.S. sanctions laws. Yet many U.S. companies do not understand the significance of these laws....more

Foley Hoag LLP

First A Ransomware Attack, Now Sanctions? New OFAC Advisory Warns of Sanctions Risks for Facilitating Ransomware Payments

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On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments... OFAC is the federal...more

King & Spalding

Ransomware: To Pay or Not to Pay?

King & Spalding on

Ransomware has emerged as one of the most virulent cybersecurity risks, affecting public and private sector alike. In recent years, ransomware attacks have become more focused, sophisticated, costly, and numerous. Threat...more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

Bilzin Sumberg on

On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

Cohen & Gresser LLP

Senate Report Exposes the U.S. Art Market as a Hotbed for Money-Laundering and U.S. Sanctions Evasion

Cohen & Gresser LLP on

A congressional report released on July 29, 2020, by the Senate’s Permanent Subcommittee on Investigations, exposes how Russian oligarchs looking to evade U.S. sanctions are able to exploit loopholes in the art industry....more

King & Spalding

Virtual Currency in Sanctioned Jurisdictions

King & Spalding on

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

Akerman LLP

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

Akerman LLP on

With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

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