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David Sewell advises banks, nonbank financial institutions, and fintech companies regarding banking law and regulation.

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

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