News & Analysis as of

U.S. Treasury Office of Foreign Assets Control (OFAC) Money Laundering

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

Holland & Knight LLP on

The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...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

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

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (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

Cadwalader, Wickersham & Taft LLP

U.S. Deploys Pincer Maneuver on Perceived Crypto Abuses

Crypto’s two calling cards, decentralization and anonymity, can lead to abuses, such as money laundering and tax evasion. The U.S. Treasury has long combatted crypto money laundering...more

Patton Sullivan Brodehl LLP

The “DAO Jungle” Chronicles: Federal Judge Upholds Treasury Department’s Sanction of Tornado Cash for Involvement in Laundering...

In two prior posts, this blog tracked the ongoing intrigue of how the various branches of the United States government interact with blockchain and cryptocurrency organizations. We discussed the Wyoming law allowing...more

Ballard Spahr LLP

All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury...

Ballard Spahr LLP on

Complex Civil and Criminal Cases Converge - On August 17, 2023, Judge Robert Pitman of the federal district court for the Western District of Texas issued an Order granting summary judgment for the U.S. Treasury Department...more

BakerHostetler

Court Upholds Tornado Cash Sanctions; New Crypto Products Launch; IRS Proposes Digital Asset Regulations; Crypto Enforcement and...

BakerHostetler on

District Court Upholds Tornado Cash Sanctions, DOJ Charges Founders - On August 17, a Texas federal court found that Tornado Cash, a crypto mixer (which obscures the source of crypto transactions) is an entity that can be...more

Orrick, Herrington & Sutcliffe LLP

OFAC announces sanctions tied to Central America drug trafficking

On February 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13581, against an individual based in Honduras and another individual based in Nicaragua...more

K2 Integrity

The North Korean Crypto Threat

K2 Integrity on

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

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

BakerHostetler

Crypto Products Launch, Gain Approvals; OFAC Sanctions Crypto Mixer; SEC Publishes ICO Consent Order; Report Cites Criminal Use of...

BakerHostetler on

NY DFS Approves Crypto Platform, Prepaid Crypto Card to Launch in Argentina - According to a press release this week, the New York State Department of Financial Services (NY DFS) has authorized two subsidiaries of Zero...more

Latham & Watkins LLP

OFAC Sanctions Decentralized Virtual Currency Mixer

Latham & Watkins LLP on

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

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...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

Ballard Spahr LLP

U.S. Treasury Identifies Ongoing and Emergent Money Laundering Risks and Vulnerabilities

Ballard Spahr LLP on

On March 1, 2022, the U.S. Department of the Treasury (“Treasury”) published its National Risk Assessment for Money Laundering, Terrorist Financing, and Proliferation Financing (the “NMLRA”), identifying the national threats,...more

Bracewell LLP

DOJ Trumpets New Multi-Faceted Cryptocurrency Task Force: What this Means for You

Bracewell LLP on

In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on

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

Sheppard Mullin Richter & Hampton LLP

First OFAC Sanctions Against a Cryptocurrency Exchange: Could the Designation of SUEX Signal an Enforcement Trend to Combat...

On September 21, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Morrison & Foerster LLP

OFAC Issues Advisory Highlighting Art Trade No “Goghs”

Morrison & Foerster LLP on

On October 30, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published an advisory highlighting potential sanctions risks arising from dealings in “high-value artwork” (with “particular...more

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