In one of the first criminal cases brought under US sanctions laws involving cryptocurrency transactions, a federal magistrate judge approved the Department of Justice’s criminal complaint. In the opinion unsealed on May 13, 2022, US Magistrate Judge Zia M. Faruqi ruled that the Department of Justice demonstrated probable cause in accusing an unnamed defendant of transmitting more than $10 million in bitcoin to a “comprehensively sanctioned” country.

Continue Reading Judge Rules in Criminal Sanctions Case Involving Cryptocurrency

On May 4, 2022, California Governor Gavin Newsom signed executive order N-9-22 regarding blockchain and crypto assets, with the objective to “spur responsible web3 innovation, grow jobs, and protect consumers.” According to the accompanying press release, the executive order “aims to create a transparent regulatory and business environment for web3 companies which harmonizes federal and California approaches, balances the benefits and risks to consumers, and incorporates California values such as equity, inclusivity, and environmental protection.”
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On February 28, 2022, the Emirate of Dubai enacted Law No. 4 of 2022 on the Regulation of Virtual Assets and established the Dubai Virtual Assets Regulatory Authority. By establishing a legal framework for businesses related to virtual assets, including crypto assets and non-fungible tokens, this landmark law reflects Dubai’s vision to become one of the leading jurisdictions for entrepreneurs and investors of blockchain technology.
Continue Reading Dubai Issues Its First Crypto Law Regulating Virtual Assets

On March 31, 2022, the staff of the Division of Corporation Finance and the Office of the Chief Accountant of the SEC issued Staff Accounting Bulletin No. 121 (SAB 121), which “adds interpretive guidance for entities to consider when they have obligations to safeguard crypto-assets held for their platform users.” SAB 121 highlights the enhanced technological, legal and regulatory risks associated with safeguarding digital assets, as compared with more traditional asset classes.
Continue Reading SEC Issues SAB 121 Providing Accounting Guidance for Companies that Safeguard Digital Assets

On March 24, 2022, the US Attorney for the Southern District of New York announced charges against two defendants and alleged an ongoing fraud involving the sale of nonfungible tokens. The federal criminal case is among the first involving NFTs and foreshadows further regulatory scrutiny of the popular digital asset class.
Continue Reading DOJ Brings Criminal Charges Against Two Defendants in NFT Fraud

On March 9, 2022, the Biden Administration released its much-anticipated “Executive Order on Ensuring Responsible Development of Digital Assets”. The White House describes the Executive Order as the “first whole-of-government strategy” on digital assets and attempts to strike a balance between encouraging innovation and US leadership in the digital asset space, while signaling an appetite to protect against a variety of stated risks through additional regulation and legislation. 
Continue Reading President Biden Issues Executive Order on Digital Assets

On March 8, 2022, President Biden issued an Executive Order prohibiting the importation of Russian-origin oil, liquified natural gas, and coal into the United States and prohibiting US persons from making new investments in Russia’s energy sector. On March 9, 2022, President Biden issued an Executive Order directing US government agencies to study and report on cryptocurrencies and other digital assets and consider, among other things, the use of digital assets to circumvent US sanctions.
Continue Reading US Sanctions Target Russia’s Energy Sector and Ban Imports of Russian Oil, LNG, and Coal as Enforcement Efforts Increase and Agencies Consider Cryptocurrency and Other Digital Assets

On February 28, 2022, the US Department of Treasury’s Office of Foreign Assets Control issued further sanctions on Russia’s Central Bank, National Wealth Fund, and Ministry of Finance, and announced regulations to implement Executive Order 14024 under the Russia Harmful Foreign Activities Sanctions Program. On February 24, 2022, the Department of Commerce’s Bureau of Industry and Security issued an immediate final rule implementing sanctions under the Export Administration Regulations.
Continue Reading US Sanctions Tighten on Russia’s Financial Sector and Technology Imports