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Mar 26, 2025 | 
consumerfinancemonitor.com | Kelly A. Lenahan-Pfahlert
On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory
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Dec 6, 2024 | 
jdsupra.com | Siana Danch |Peter Hardy |Kelly A. Lenahan-Pfahlert
In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado Cash, “an open-source, crypto-transactions software protocol that facilitates anonymous transactions by obfuscating the origins and destinations of digital asset transfers.” The opinion, which reversed the ruling of the District Court, is here.
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Oct 28, 2024 | 
jdsupra.com | Kelly A. Lenahan-Pfahlert
On October 22, 2024, the U.S. Court of Appeals for the Second Circuit ruled that Türkiye Halk Bankası A.Ş. (“Halkbank”), owned by the Republic of Turkey, can be prosecuted for allegedly helping Iran evade U.S. sanctions and committing related money laundering and bank fraud. The court rejected Halkbank’s claim of immunity, stating that foreign state-owned companies are not protected from prosecution for commercial, non-governmental activities under U.S. common law.
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Sep 5, 2024 | 
jdsupra.com | Kelly A. Lenahan-Pfahlert
On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to anti-money laundering (“AML”) compliance. Nordea, headquartered in Helsinki, Finland, operates globally, including through a licensed branch in New York, which has its own AML and transaction monitoring requirements.
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Jul 3, 2024 | 
jdsupra.com | Kelly A. Lenahan-Pfahlert
On June 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplemental advisory to alert U.S. financial institutions about emerging trends in the illicit fentanyl supply chain. The supplemental advisory emphasized the increasing involvement of Mexico-based transnational criminal organizations (“TCOs”) in the procurement of fentanyl precursor chemicals and manufacturing equipment from suppliers in the People’s Republic of China (“PRC”).
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May 22, 2024 | 
law360.com | Peter Hardy |Kelly A. Lenahan-Pfahlert
By Peter Hardy and Kelly Lenahan-Pfahlert (May 22, 2024, 4:49 PM EDT) -- Tracking and tracing illicit activities conducted through digital currencies is difficult. The process can be very time- and resource-intensive.... Law360 is on it, so you are, too. A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.
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May 22, 2024 | 
law360.co.uk | Peter Hardy |Kelly A. Lenahan-Pfahlert
ADVERTISEMENT Don't want ads? Subscribe or login now. By Peter Hardy and Kelly Lenahan-Pfahlert (May 22, 2024, 4:49 PM EDT) -- Tracking and tracing illicit activities conducted through digital currencies is difficult. The process can be very time- and resource-intensive....
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May 22, 2024 | 
ballardspahr.com | Peter Hardy |Kelly A. Lenahan-Pfahlert
Peter Hardy and Kelly Lenahan-Pfahlert, both members of Ballard Spahr's Anti-Money Laundering team, examine a recent ruling by the U.S. District Court for the District of Columbia in this Law360 article. The court's decision, which found the defendant guilty of money laundering via Bitcoin, has potentially significant implications for future cases involving cryptocurrency transactions and digital currency-related crimes. Read the full article here.
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May 8, 2024 | 
jdsupra.com | Celia Cohen |Peter Hardy |Kelly A. Lenahan-Pfahlert
On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the “Third-Party Risk Management: A Guide for Community Banks” (the “Guide”), presenting it as a resource for community banks to bolster their third-party risk management programs, policies, and practices.
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Mar 19, 2024 | 
jdsupra.com | Kelly A. Lenahan-Pfahlert
It is challenging for law enforcement to track down and trace illicit activities conducted through digital currencies. The process can be very time- and resource-intensive. Further, securing charges and arrests, and subsequent convictions, often requires the strong support of traditional sources of evidence, such as fact witness testimony and electronic communications. Nonetheless, blockchain analytics is a key component of the government’s ability to pursue such cases.
