News & Analysis as of July 18, 2025

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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 -

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

Bressler, Amery & Ross, P.C. on 6/24/2025

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

The Shadow Financial System

White & Case LLP on 6/18/2024

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

Implications of FinCEN’s Notice of Proposed Rulemaking on Virtual Currency Mixers

K2 Integrity on 1/29/2024

On 17 January 2024, K2 Integrity hosted a webinar on FinCEN’s Notice of Proposed Rulemaking on virtual currency mixers and the implications of this first-of-its-kind 311 designation on the virtual currency industry. Elizabeth...more

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on 11/14/2023

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

FinCEN Targets Convertible Virtual Currency Mixing to Combat Terrorist Financing and Other Illegal Transactions

Morrison & Foerster LLP on 10/27/2023

Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - September 2023

Lowenstein Sandler LLP on 9/7/2023

1. OFAC Imposes Sanctions on Russian Elites Who Were Board Members of Alpha Group- On Aug. 11, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Russian individuals, Petr...more

Material Investment Management Developments and Template Annual Compliance Checklists for Registered Investment Advisers, Exempt...

Lowenstein Sandler LLP on 4/7/2023

Lowenstein Sandler’s Investment Management Group is pleased to provide you with the summaries and checklists described below. Summaries of recent legal developments with respect to: •SEC’s 2023 Examination Priorities- ...more

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

The Volkov Law Group on 12/9/2022

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

The North Korean Crypto Threat

K2 Integrity on 10/17/2022

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

The Crypto Weekly - September 2022 Issue #2

Kelley Drye & Warren LLP on 9/15/2022

The below articles and industry developments have been identified by Kelley Drye and Warren’s Blockchain and Cryptocurrency practice group as relevant during the week of September 7 – September 13. We hope you find this...more

Top PHive Crypto Enforcement Notes: September Edition

Paul Hastings LLP on 9/7/2022

Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts

Skadden, Arps, Slate, Meagher & Flom LLP on 8/25/2022

A flurry of legal and enforcement activity has arisen over the last two weeks across a wide range of areas in the Web3 space, including actions by the Securities and Exchange Commission, the Office of Foreign Assets Control,...more

The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies

Sheppard Mullin Richter & Hampton LLP on 6/3/2022

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

OFAC Focuses on Cybercrime by Sanctioning the Hydra Darknet Market and GARANTEX Cryptocurrency Exchange

The Volkov Law Group on 4/13/2022

Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April...more

Global Markets May Face Risk of Virtual Currency Abuse as Russian Actors Seek to Circumvent Sanctions

K2 Integrity on 3/14/2022

The United States, the United Kingdom, and European Union have led a broad international coalition imposing a sweeping and unprecedented range of economic and financial sanctions against Russia and Belarus in response to...more

Review of Sanctions and Export Control Developments in 2021 and What to Expect in 2022

Foley Hoag LLP - White Collar Law &... on 2/25/2022

This is the fifth post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in State AG enforcement. Up next: SEC Enforcement in 2022: A Look Ahead. ...more

OFAC Year-in-Review 2021 Part II – Lessons Learned from OFAC’s 2021 Enforcement Actions

Morrison & Foerster LLP on 2/9/2022

Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more

Year-end Crypto Roundup — Five Key Concepts About the U.S. Government’s Recent Actions on Virtual Currency and Ransomware

Orrick, Herrington & Sutcliffe LLP on 12/30/2021

The innovative use of virtual currencies is hotter than ever, but so is a dark side of these instruments: their exploitation in ransomware schemes. This year, since January 2021, ransomware attacks have increased...more

OFAC Warns FFIs And Crypto Sector On Ransomware Attacks

Foodman CPAs & Advisors on 12/14/2021

During the first half of 2021, 68 different ransomware attacks extracted approximately $600 million from victims across the United States. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) says that the...more

Ransomware and OFAC Sanctions Compliance

The Volkov Law Group on 11/4/2021

We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering...more

Trade Matters - November 2021

Lowenstein Sandler LLP on 11/3/2021

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

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

Cooley LLP on 10/29/2021

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC’s...more

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Proskauer - Blockchain and the Law on 10/28/2021

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

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

Bracewell LLP on 10/27/2021

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

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

The Volkov Law Group on 10/27/2021

In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry. For seasoned compliance veterans, it ends up reading like a refresher...more

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