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]
OFAC Releases New Detailed Guidance for the Digital Currency Industry
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
OFAC Issues Second Ransomware Advisory and Designates Virtual Currency Exchange for Sanctions
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
The Anti-Money Laundering Act of 2020: A Survey of Key Provisions and Practice Takeaways
The AMLA 2020 includes sweeping reforms updating and modernizing U.S. anti-money laundering laws, many of which have implications beyond financial institutions regulated under the Bank Secrecy Act.
This multipart series will discuss key takeaways, including (1) new corporate beneficial ownership disclosure requirements; (2) enhanced whistleblower program; (3) expanded subpoena authority over foreign financial institutions accessing