On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and sanctions which we have previously discussed here and here.
Fatema Merchant is a partner in the Governmental and White Collar Defense and Corporate Investigations Practice Groups in the firm's Washington, D.C. office. Fatema is the Office Managing Partner of the firm's Washington, D.C. office and leads the Sanctions Team at Sheppard Mullin.
With the advent of blockchain technology, vendors are increasingly accepting payments of goods, including artwork, with digital currency. The decentralized nature of digital currency makes it attractive for a lot of reasons, but it also makes legal oversight a challenge. Add to that the emerging (or already emerged) high-value market for digital art. For example, Beeple’s Non-Fungible Token (“NFT”) collection sold for more than $69 million at an auction, and a CryptoPunk NFT sold for $23 million.
Continue Reading Money Laundering and High-Value Art: Treasury’s Study Discusses Financial Crimes and NFTs
The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for facilitating financial transactions for ransomware actors. In total, OFAC designated Chatex and 57 cryptocurrency addresses (associated with digital wallets) as Specially Designated Nationals (SDNs). OFAC took this action pursuant to Executive Order 13694, issued in 2015, which provides broad sanctions authority to address the national security threat posed by malicious cyber-actors outside the United States.
Continue Reading OFAC Enforcement Impacts NFTs: As Crypto Enforcement Ramps Up to Combat Ransomware, Robust Compliance is Key
*This is an updated version of the Global Trade Law Blog’s December 10th post .
- Emerging technology sectors are being reviewed now for new export controls that could take effect in 2019 (list below).
- You may submit comments on the criteria the U.S. government will use to determine what technologies are subject to export controls.
- The deadline for comments has been extended to January 10, 2019.
- We can help.