News & Analysis as of

Virtual Currency Economic Sanctions

Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender... more +
Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency.    less -
Alston & Bird

NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict

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Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more

Bressler, Amery & Ross, P.C.

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more

BakerHostetler

Weekly Blockchain Blog - December 2024 #3

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Digital Asset Companies Achieve Licenses, Launch Stablecoin Products - According to a recent press release, Anchorage Digital, a digital asset platform and infrastructure provider, announced that the New York State...more

Hogan Lovells

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

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The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

Orrick, Herrington & Sutcliffe LLP

5th Circuit reverses and remands cryptocurrency software case stating OFAC exceeded its authority

On November 26, the U.S. Court of Appeals for the Fifth Circuit reversed and remanded a decision by the district court regarding the Office of Foreign Assets Control’s (OFAC) designation of a virtual currency mixer software...more

Ballard Spahr LLP

Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts

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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

Conyers

International Sanctions Requirements for Virtual Asset Service Providers: a Cayman Perspective

Conyers on

As the war continues to rage on the Eastern front between Russia and Ukraine, the financial sanctions resulting from the initial invasions and ongoing conflict seem likely to continue to play a significant part in the global...more

Mayer Brown

Russia/Ukraine Sanctions Update - Month of September

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I.  US SANCTIONS - U.S. Department of the Treasury Acts Against Russian Virtual Currency Exchanges: On September 26, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network issued an...more

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

American Conference Institute (ACI)

[Event] 24th National Forum on Prepaid Accounts Compliance - April 8th, New York, NY

The 24th National Forum on Prepaid Accounts Compliance will address the latest developments impacting the prepaid industry and provide answers to the most pressing questions and challenges being faced by practitioners in this...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

Foodman CPAs & Advisors

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

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El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more

Foodman CPAs & Advisors

Terrorist Financing FinCEN Red Flags

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On 10/20/23, Terrorist Financing Red Flags were issued by FinCEN to assist financial institutions in identifying funding streams for the terrorist organization Hamas in response to Hamas’s terrorist attack on the people of...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

Ballard Spahr LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

OFAC sanctions actors facilitating DPRK virtual currency laundering

On April 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Orders 13722 and 13382, against three individuals for providing material support to the Democratic...more

Foley Hoag LLP

Navigating the International Trade & National Security Landscape

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The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more

Sheppard Mullin Richter & Hampton LLP

OFAC Finds Digital Assets Trading Platform in Violation of Sanctions

On March 31, 2023, the Office of Foreign Assets Control (OFAC) announced a $72,230.32 settlement agreement with Uphold HQ Inc. (Uphold), a global multi-asset digital trading platform, in connection with 152 apparent...more

Morrison & Foerster LLP

OFAC Year in Review 2022 – Part 1

2022 was an unprecedented year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). While the sweeping new U.S. sanctions imposed against Russia and Belarus in unparalleled...more

Husch Blackwell LLP

International Trade Law: 2022 Year in Review & Outlook for 2023

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We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might...more

The Volkov Law Group

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

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Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more

Troutman Pepper Locke

OFAC Settles With Kraken for $362,158: Maximum Penalty Avoided

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On November 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $362,158.70 settlement with Payward, Inc. d/b/a Kraken. The Delaware-incorporated virtual currency exchange allegedly...more

Ballard Spahr LLP

Kraken Settlement Demonstrates Importance of Sanctions Monitoring for Transactions — Not Just When Onboarding Customers

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The Office of Foreign Assets Control (“OFAC”) announced (here and here) yesterday that virtual currency exchange Payward, Inc. – better known as Kraken – has agreed to pay $362,158.70 in order to settle its potential civil...more

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