The Federal Reserve Board, on August 15, 2022, issued final guidelines for regional Reserve Banks to use when considering applications for Federal Reserve “master accounts”—deposit accounts that enable direct access to the Federal Reserve’s payment systems and provide critical infrastructure to financial institutions operating in the United States. The final guidelines comprise a set of

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of virtual currency since its creation in 2019 [, including] over $455 million stolen by the Lazarus Group[,]” a Democratic People’s Republic of Korea (DPRK) state-sponsored hacking group that OFAC identified for sanctions in 2019, in what the agency characterized as the largest known virtual currency heist to date.[1]Continue Reading OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

Non-fungible tokens have been widely adopted across a variety of industries. The fast-developing NFT ecosystem of technical and commercial innovation is aimed at the promise of bridging physical world concepts of uniqueness and scarcity with the digital world. As with all forms of technical innovation, NFTs pose unique legal challenges to participants in this ecosystem.

Weekly Blockchain Focus

  • Securities and Exchange Commission announces judgments entered against BitConnect’s lead national promoter
  • Commissioner Stump calls for clarity before bringing any more enforcement actions
  • Cryptocurrency CEOs speak to the House Committee on Financial Services
  • Gibraltar to use blockchain for digital identification
  • India to ban cryptocurrencies as a form of payment
  • Bank for International Settlements discusses decentralized finance in its quarterly report

 
Continue Reading Blockchain Week in Review: Week of December 10, 2021

The growth and adoption of secure digital identity systems, including digital health status systems containing health records, could provide a uniform and reliable response to calls for health credential verification. In this white paper, Perkins Coie authors examine the three pillars essential to successfully developing and deploying these technologies.

As these systems are forced

On October 15, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed statement to date on its expectations for participants in this rapidly growing industry. This guidance expands on the five pillars of OFAC’s 2019 Framework by

Agency’s Focus on Cryptocurrency and Blockchain Continues

On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions risks associated with ransomware payments”—almost one year after issuing the first such guidance—and simultaneously imposed sanctions on SUEX, a virtual currency exchange accused

Weekly Focus:

  • The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches
  • The Department of Treasury Sanctions Individuals for Laundering Cryptocurrency for Lazarus Group
  • Guilty Plea in DeepDotWeb Criminal Proceedings
  • Japan Announces Plans to Adopt FATF Travel Rule for Crypto
  • Canadian Securities Organizations Unveil Guidance on Treatment of Cryptocurrencies

Continue Reading Blockchain Week in Review: Week of April 2, 2021

Weekly Focus:

  • Federal Regulation Actions Frozen Pending Review from New Administration
  • New Administration Appoints New Agency Leads
  • OCC Issues Ruling Permitting National Banks to Use Certain Blockchain Technologies
  • CFPB Finalizes Rule on the Role of Supervisory Guidance
  • Federal banking regulators issue FAQs on SAR filing obligations.
  • Dutch Gambling Regulator Fines Virtual Coin Gaming Company

Continue Reading Blockchain Week in Review: Week of January 22, 2021

Perkins Coie is pleased to announce that it has obtained no-action relief from the Securities and Exchange Commission Staff that clears the way for its client IMVU Inc., to sell VCOIN, a blockchain-based digital asset, as a transferable non-security to its users worldwide.

IMVU is the world’s largest avatar-based social platform with a global network