FinCEN’s Action Against BTC-e: Another Effort to Bring Law and Order to the Virtual Currency Frontier

By Jenny E. Cieplak, Thomas Hanusik & Sarah Bartle

August 23, 2017

On July 26, 2017, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) assessed a civil money penalty of more than $110 million against BTC-e, a Russian-headquarted, internet-based virtual currency exchanger, and a $12 million penalty against its Russian owner, Alexander Vinnik. On that same day, the Department of Justice announced a 21-count indictment against Vinnik for money laundering and the operation of an unlicensed money services business (MSB). Vinnik was arrested in Greece…

International Trade Law

A $250,000 Settlement with FinCEN Puts AML Compliance Officers in the Cross-Hairs

By Cari Stinebower, Thomas Hanusik & Sarah Bartle

May 10, 2017

May.10.2017 MoneyGram’s ex-Chief Compliance Officer, Thomas Haider, on May 3 settled alleged anti-money laundering (AML) compliance violations with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network for $250,000, according to announcements by FinCEN and U.S. Attorney’s Office for the Southern District of New York. It appears to be the largest penalty FinCEN ever has imposed on an individual. The settlement resolves an action that FinCEN brought in federal district court to enforce its…

Government Contracts Legal Forum

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs

By Lorraine M. Campos & Sarah Bartle

February 24, 2017

On February 8, 2017, the Department of Justice Fraud Section posted a new guidance document on its website entitled, “Evaluation of Corporate Compliance Programs” (“Compliance Guidance”). This Compliance Guidance, comprised of a number of topics and questions, comes a little over a year after the Fraud Section hired Hui Chen as its resident compliance expert. Tapping into her experience as both a prosecutor and a compliance professional at several large multinational companies, Ms. Chen…

Government Contracts Legal Forum

For Whom Does the Appeal Clock Toll? Vitiation vs. Finality

By Steve McBrady, Skye Mathieson & Sarah Bartle

January 12, 2016

In Guardian Angels Med. Serv. Dogs Inc. v. U.S. (Jan. 8, 2016), the Federal Circuit held that a CO’s request to evaluate additional information after a default termination “vitiated the finality” of the termination and reset the 12-month appeal clock, even though the CO neither received new information nor spent any time reconsidering her decision. Reversing the CFC’s dismissal of the appeal as time-barred, the court held that, when a CO “evince[s] a clear willingness…

Sarah Bartle

FinCEN’s Action Against BTC-e: Another Effort to Bring Law and Order to the Virtual Currency Frontier

A $250,000 Settlement with FinCEN Puts AML Compliance Officers in the Cross-Hairs

DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs

For Whom Does the Appeal Clock Toll? Vitiation vs. Finality

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