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U.S. Treasury SDN List Cryptocurrency

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

Constangy, Brooks, Smith & Prophete, LLP

You’ve been hit with ransomware. Think twice before you pay.

You've been hit by a ransomware attack, and a cybercriminal group is demanding a cryptocurrency payment in exchange for your data's safe return. Should you pay? Deciding whether to pay a ransom is an internal business...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

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

Dorsey & Whitney LLP

U.S. Treasury Department Takes Action Against Russian Darkmarket Entity as Latest Government Move Against Cybercrime

Dorsey & Whitney LLP on

On April 5, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) in the U.S. Department of the Treasury named Genesis Market to OFAC’s Specially Designated Nationals List (“SDN List”). Genesis Market is...more

Paul Hastings LLP

Top PHive Crypto Enforcement Notes: October Edition

Paul Hastings LLP on

We knew there would be plenty to write about each month, and so we start with a mention of the White House’s Framework for Responsible Development of Digital Assets, issued on September 16, 2022....more

BakerHostetler

NFT Initiatives Launch; OFAC Adds Crypto Public Keys to SDN List; Treasury Dept. Publishes Crypto Reports; Crypto Enforcement and...

BakerHostetler on

Non-Fungible Marketing: Brands Continue to Launch NFTs - A South Korean technology company has reportedly launched a weeklong promotion in the metaverse. According to reports, the virtual events occurred across multiple...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

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

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

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

Sheppard Mullin Richter & Hampton LLP

OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key

The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...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

Latham & Watkins LLP on

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

Perkins Coie on

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

WilmerHale

OFAC Imposes New Sanctions to Thwart Ransomware

WilmerHale on

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more

Akin Gump Strauss Hauer & Feld LLP

OFAC Adds Iranian Bitcoin Exchangers’ Names and Wallet Addresses to SDN List, Ushers in “New Approach” to Sanctions Enforcement

• On November 28, 2018, OFAC designated two Iran-based individuals who helped exchange cryptocurrency (bitcoin) into fiat currency on behalf of alleged ransomware perpetrators who targeted U.S. businesses and municipal...more

WilmerHale

OFAC Identifies Digital Currency Addresses in Sanctions Designations and Provides FAQs on Digital Currency Compliance

WilmerHale on

On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more

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