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Virtual Currency Regulatory Requirements 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

White & Case LLP

The Shadow Financial System

White & Case LLP on

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

Foodman CPAs & Advisors

Deficiencies or Weaknesses in an OFAC Sanctions Compliance Program can lead to OFAC Administrative Actions

On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”.  The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more

Sheppard Mullin Richter & Hampton LLP

Digital Cops and Cyber Robbers: OFAC Guidance on Crypto Currency

A lot of us in the sanctions compliance world were wondering whether and when OFAC would issue official guidance on its application of sanctions in the digital currency world. On March 18, OFAC issued five FAQs related to...more

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