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On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments on the sanctions risks associated with facilitating ransomware payments. OFAC, with assistance from the FBI, also designated SUEX OTC, S.R.O., as a malicious cyber actor, the first such sanctions designation against a virtual currency exchange.…
Continue Reading OFAC Designates Virtual Currency Exchange as Malicious Cyber Actor

The US Department of the Treasury’s Office of Foreign Assets Control settled with BitPay, Inc. for $507,375 to resolve 2,102 apparent violations of multiple US sanctions programs for allowing individuals located in sanctioned jurisdictions to use digital currency on its platform to transact with merchants in the United States and elsewhere.…
Continue Reading OFAC Settles with Digital Currency Services Provider for Apparent Violations of Multiple Sanctions Programs

Amid the rise of digital currency services, the US Department of the Treasury’s Office of Foreign Assets Control published a cautionary tale on December 30, 2020, discussing a recent settlement with BitGo, Inc., a California-based technology company that facilitates digital currency transactions and provides non-custodial digital wallet management services.…
Continue Reading OFAC Settlement Highlights Risks for Those Dealing in Digital Currencies

The US Treasury Department recently announced its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (the 2020 Strategy). The 2020 Strategy identifies the US government’s top anti-money laundering and countering the financing of terrorism priorities and serves as a roadmap of Treasury’s plan to stay ahead of evolving illicit finance threats. Digital assets feature heavily in the 2020 Strategy.…
Continue Reading Digital Assets Featured in US Treasury 2020 National Strategy

As recently reported on the Hunton Privacy & Information Security Law Blog, the European Commission released a suite of documents including its White Paper on Artificial Intelligence and two communications—its European strategy for data and a Digital Strategy document. …
Continue Reading European Commission Releases White Paper on Regulation of AI and Communications on Digital and Data Strategies for Europe

As reported last week on the Hunton Insurance Recovery Blog, crypto-asset losses continue to rise and the industry is taking steps to protect clients and investors through insurance. Crypto-exchange and custody provider, Gemini Trust Company, LLC (“Gemini”), recently launched its own captive insurance provider, Nakamoto, Ltd. Captive insurance is an alternative to self-insurance whereby a company creates a licensed insurance company to provide coverage for itself.…
Continue Reading Captive Insurance Offers Protection to Growing Crypto-Currency Industry

In 2019, Hunton Andrews Kurth LLP’s structured finance and securitization team closed a number of substantial transactions, developed novel structures for our clients and advised on important tax, regulatory and other industry developments, including emerging uses of blockchain solutions.…
Continue Reading Structured Finance and Securitization 2019 Year in Review