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ARTICLE · 23 NOVEMBER 2022

FinCEN And OFAC Issue First Joint Action In Cryptocurrency Market

McGlinchey Stafford
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On October 11, 2022, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) acted in parallel to issue the first joint action...

United StatesTechnology
Rachael Aspery
Rachael Aspery
Aaron P. Kouhoupt
Aaron P. Kouhoupt

On October 11, 2022, the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) acted in parallel to issue the first joint action in the cryptocurrency market against Bittrex. Bittrex was a convertible virtual currency (CVC) platform with offices primarily in Washington State and was licensed as a money services business (MSB) with FinCEN. As a licensed MSB, Bittrex was required to develop, implement, and maintain an effective anti-money laundering (AML) program that was reasonably designed to prevent money laundering and the potential financing of terrorist activities.

OFAC entered into the largest settlement in its history ($24 million) claiming that Bittrex processed transactions that violated OFAC sanctions. OFAC identified that Bittrex conducted more than 116,000 transactions, valued at over $260 million, with entities and individuals located in jurisdictions subject to comprehensive OFAC sanctions, including transactions

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