On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixing service Tornado Cash, which OFAC said has been used to launder billions of dollars in virtual currency, including $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (“DPRK”) state-sponsored hacking group
Virtual Currency
Treasury Agencies Issue Virtual Currency Sanctions Compliance Guidance and Ransomware Trends Statistics
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued its first-ever sanctions compliance guidance (the “OFAC Guidance” or “Guidance”) for the virtual currency industry. The Guidance represents a focused effort by OFAC to highlight sanctions risks present in the virtual currency industry, which has experienced tremendous growth…
OFAC Issues Updated Guidance on Ransomware Attacks and Imposes First Sanctions Designation on a Virtual Currency Exchange
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated advisory on potential sanctions risks for companies that facilitate ransomware payments in response to cyberattacks, guidance on preventative measures companies can implement to mitigate such risks, and criteria that OFAC will consider as mitigating factors in…
New York Governor Kathy Hochul Announces Nomination of Adrienne Harris as Superintendent of the New York Department of Financial Services
On August 31, 2021, New York Governor Kathy Hochul announced the nomination of Adrienne Harris as the Superintendent of the New York Department of Financial Services – New York’s top financial regulator and a key regulator in the banking, anti-money laundering, fintech, insurance, and cryptocurrency spaces. Harris, whose nomination is still subject to confirmation, has…
FinCEN and CFTC Announce $100 Million in Regulatory Settlements With Foreign Cryptocurrency Exchange for BSA Violations and Failures to Register
On August 10, 2021, the Financial Crimes Enforcement Network (“FinCEN”) and the Commodity Futures Trading Commission (“CFTC”) jointly announced $100 million in civil settlements with five entities responsible for the operations of BitMEX, a foreign peer-to-peer convertible virtual currency (“CVC,” or cryptocurrency) derivatives exchange. FinCEN said that the settlement represents FinCEN’s first enforcement action against…