2021-03-08 17:45:17

Cryptocurrency Offers No Escape From International Sanctions

Robert A. Schwinger

Among the conclusions offered in “Cryptocurrency Enforcement Framework” issued by the Department of Justice this past fall (see generally R. Schwinger, “Blockchain Law: DOJ’s ‘Cryptocurrency Enforcement Framework’,” NYLJ (Jan. 15, 2021)) was the ominous warning that “cryptocurrency presents a troubling new opportunity for individuals and rogue states to avoid international sanctions and to undermine traditional financial markets, thereby harming the interests of the United States and its allies.” A spate of recent government enforcement action shows that the United States is not hesitating to tackle cryptocurrency activity being used to try to circumvent the prohibitions of U.S. economic sanctions.

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