Kelly A. Lenahan-Pfahlert

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.

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.

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.

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”).

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.