The Department of the Treasury’s recently issued Illicit Finance Risk Assessment of Decentralized Finance is principally intended to provide insight on how illicit actors are abusing decentralized finance (DeFi) services, as well as anti-money laundering (AML) and countering the financing
Blockchain Blog
The Blockchain Blog, published by Steptoe LLP, focuses on legal and regulatory developments related to blockchain technology, cryptocurrencies, and digital assets. It covers topics such as regulatory approvals and enforcement actions by agencies like the SEC and CFPB, the evolving legal framework for crypto products including bitcoin exchange traded products (ETPs) and stablecoins, and the impact of new rules on digital payments and financial promotions involving cryptoassets. The blog also analyzes jurisdiction-specific regulatory roadmaps, such as those in the UK, and discusses compliance challenges and supervisory authority over nonbank digital payment providers.
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In Unprecedented Action FinCEN Identifies Virtual Currency Exchange as Primary Money Laundering Concern
On January 18, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order identifying the virtual currency exchange Bitzlato Limited (Bitzlato) as a “primary money laundering concern” in connection with Russian illicit finance. The order,…
Proposed Rule Lays Out Who Will Have Access to New Corporate Beneficial Ownership Information
By Evan Abrams & Dave Stetson
On December 16, FinCEN issued a notice of proposed rulemaking (NPRM) entitled “Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities.” The NPRM is intended to implement the Corporate Transparency Act (CTA) and, in particular, to…
FTX: An Explainer on What Happened and What’s Next?
Reports of FTX Group’s demise has been inescapable since news first broke of potential insolvency and misuse of customer funds. This blog post provides some background on the situation as well as some thoughts on what is likely to come…
The Storm Is Here
By Jason Weinstein & Alan Cohn
With the collapse of FTX and Alameda so close on the heels of Celsius, one thing is clear – the regulatory and enforcement storm so many anticipated coming to crypto is now here. Unfortunately, regardless of what the facts surrounding…
OFAC and FinCEN Announce Enforcement Actions Against Bittrex
On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN) announced enforcement actions against Bittrex, Inc. (Bittrex), a privately-owned digital asset trading platform based in Bellevue, Washington, for…
OECD Releases New Global Tax Reporting Framework for Cryptocurrency
By Lisa Zarlenga & Nick Sutter
On October 10, 2022, the Organisation for Economic Co-Operation and Development (OECD) released its new global tax reporting standards for cryptocurrency and other digital assets, the Crypto-Asset Reporting Framework (CARF) and Amendments to the Common Reporting Standard.[1] The CARF…
New UK Sanctions Legislation Expands Mandatory Financial Sanctions Reporting Obligations to Include Crypto Providers
On August 30, 2022, further amendments to the UK’s nine thematic and 29 geographic sanctions regulations came into effect, which expand financial sanctions reporting obligations to cryptoasset exchanges and custodian wallet providers. The amendments, which were introduced under the Sanctions…
DFS’s First Enforcement Action Against a Blockchain Company: Lessons Learned
On August 1, Robinhood Crypto, LLC (RHC) entered a consent order with the New York State Department of Financial Services (DFS) requiring RHC to pay a $30 million fine for violating (1) New York’s virtual currency regulatory regime known as…
OFAC Designates Tornado Cash in First Action Against a Decentralized Platform
On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions on the decentralized digital asset mixer Tornado Cash. The action marks the first time OFAC has targeted an on-chain…