On Jan. 25, 2024, the Hawaii Department of Commerce and Consumer Affairs Division of Financial Institutions (DFI) and the Hawaii Technology Development Corporation (collectively, the “Agencies”) jointly issued a press
Continue Reading Hawaii’s Money Transmitters Modernization Act Will No Longer Apply to Cryptocurrency ActivitiesMarina Olman-Pal
Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.
5 Trends to Watch: 2024 Blockchain
- Continued Robust Litigation and Enforcement Actions by Federal and State Regulators and Enforcement Authorities – We will likely see a similar level of anti-fraud prosecutions by the Department of Justice
California Enacts Digital Assets Licensing Law
On Oct. 13, 2023, California Governor Gavin Newsom signed CA AB39, the Digital Financial Assets Law (DFAL), which is the first comprehensive framework to regulate the digital asset market…
Continue Reading California Enacts Digital Assets Licensing LawFinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC Mixing
On Oct. 23, 2023, FinCEN published an NPRM that identifies international CVC mixing as “a class of transactions of primary money laundering concern,” and finds that imposing additional recordkeeping and…
Continue Reading FinCEN Proposes Rule to Address Money Laundering and Terrorist Financing Risks Associated with CVC MixingNYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the Greenlist
On Sept. 18, 2023, the New York State Department of Financial Services (NYDFS) issued a press release announcing updates to its ongoing oversight of the digital asset space, including (1)…
Continue Reading NYDFS Updates Guidance on Virtual Coin-Listing/Delisting Frameworks and the GreenlistFederal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related Activities
On Feb. 23, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively…
Continue Reading Federal Reserve, FDIC, and OCC Issue 2nd Joint Statement Highlighting Liquidity Risks to Banks Engaged in Crypto-Asset-Related ActivitiesFederal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking Organizations
On Jan. 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively…
Continue Reading Federal Reserve, FDIC, and OCC Issue the First Joint Statement on Crypto-Asset Risks to Banking OrganizationsCrypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering Violations
On Oct. 11, 2022, the U.S. Treasury Department announced that cryptocurrency exchange Bittrex Inc. had agreed to settle $53 million total in fines over allegations it violated sanctions and anti-money-laundering…
Continue Reading Crypto Exchange Bittrex Settles $53 Million in Fines with Treasury Department for Sanctions, Anti-Money-Laundering ViolationsRegulatory Scrutiny on the Rise of Bank and Crypto Company Dealings
Federal regulatory agencies are closely monitoring crypto-asset developments and banking organizations’ participation in the crypto-asset industry. This GT Alert covers the guidance issued by the FDIC, CFPB, and the Federal…
Continue Reading Regulatory Scrutiny on the Rise of Bank and Crypto Company Dealings
OFAC Sanctions Cryptocurrency Mixing Service for Allegedly Facilitating Money Laundering
On Aug. 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed economic sanctions on Tornado Cash, a popular cryptocurrency mixing service that allows customers to…
Continue Reading OFAC Sanctions Cryptocurrency Mixing Service for Allegedly Facilitating Money Laundering