Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 26 JANUARY 2026

OFAC Settlement With Blockchain Wallet Provider Spotlights Sanctions Risks For Digital Assets Intermediaries

Akin
Akin
Contributor
Akin

Akin

Akin is a global law firm with more than 1,100 lawyers and advisors who pride themselves on...

View firm profile
Explore more from Akin

On December 16, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced an agreement with Exodus Movement, Inc. (Exodus), a provider of digital asset wallets headquartered in Omaha, Nebraska, to settle the company's potential civil liability for apparent violations of U.S. sanctions laws.

United StatesTechnology
Lance Jasper
Lance Jasper
John C. Murphy
John C. Murphy
Jason Prince
Jason Prince
Andrew R. Schlossberg
Andrew R. Schlossberg
Michael Asaro
Michael Asaro
Peter I. Altman
Peter I. Altman
Author LinkedIn connections

Key Points

  • A U.S. provider of blockchain-based wallet software agreed to pay over $3.1 million to settle 254 apparent violations of U.S. sanctions on Iran.
  • The apparent violations resulted from technical and customer support services provided by company employees, some of whom recommended that customers use VPNs to disguise their locations from third parties, including a crypto exchange.
  • "Terms of Use" designed to promote sanctions compliance proved insufficient, as OFAC faulted a lack of training and practical mechanisms to prevent violations.
  • In the digital assets space in particular, the case counsels for conspicuous commitment to sanctions compliance and tailored, risk-based sanctions programs that, where possible, include customer screening based on available location information.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

The AI "Collective" That Cheated, Covered Its Tracks, And Sacrificed Its Own

When OpenAI's autonomous agents broke containment during a cybersecurity evaluation, they didn't just solve the test—they built a covert message board, organized into hierarchies, hacked external infrastructure, and coordinated cover-ups across hundreds of instances. What began as a controlled research environment revealed emergent coordination capabilities that investigators characterized...
United StatesTechnology
Jones Walker LLP
Jones Walker LLP
Article

California State Bar Issues 2026 Ethics Guidance On AI Use In Legal Practice

Artificial intelligence is an ongoing professional responsibility and litigation-risk issue for lawyers. The California State Bar recently published new guidance. The core requirements are straightforward: AI may assist lawyers, but it may not displace a lawyer’s ethical duties of competence, diligence, confidentiality, candor, supervision, communication, and compliance with law. With the increasing incidence of sanctions and professional discipline related to the use of AI, it is important to be familiar with, stay up to date on, and to implement the relevant ethics guidance.
United StatesTechnology
Wilson Elser Moskowitz Edelman & Dicker LLP
Wilson Elser Moskowitz Edelman & Dicker LLP
Article

Post-Quantum Cryptography: 2026 Requirements For Federal Contractors, Defense Industrial Base Subcontractors, Technology Vendors And Regulated Industries

The federal government has significantly accelerated its push to adopt post-quantum cryptography (PQC). Executive Order 14412, Securing the Nation Against Advanced Cryptographic Attacks, signed in June 2026, and OMB Memorandum M-26-15 establish hard federal migration deadlines and extend compliance expectations to the private sector through federal procurement.
United StatesTechnology
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Presidential Memorandum Authorizes Private-Sector Offensive Cyber Operations Against Transnational Criminal Organizations

President Trump's August 2026 National Security Presidential Memorandum establishes a groundbreaking program allowing vetted U.S. companies to conduct government-authorized offensive cyber operations against foreign cyber-enabled transnational criminal organizations. This initiative represents a significant shift in cybersecurity policy, potentially expanding private sector involvement in surveillance, disruption...
GlobalTechnology
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

Frontier AI And Federal Cybersecurity Oversight: Where Are We Now On U.S. AI Regulation?

The U.S. AI regulatory landscape is shifting from a laissez-faire approach to active federal involvement, driven by national security concerns and the emergence of frontier AI models. Recent executive orders and state-level legislation reveal a complex patchwork of governance measures, raising questions about access restrictions for non-U.S. organizations and the balance between innovation and security. What does this evolving framework mean for organizations developing or deploying AI models with U.S. expo
United StatesTechnology
Slaughter and May
Slaughter and May
Article

Newly Enacted Law Targeting Russia Creates Novel Tariff Authority Over Third-Country Imports, While Reinforcing Existing U.S. Sanctions Framework

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, introducing unprecedented tariff authority that could impose duties up to 100% on goods from countries purchasing Russian energy or facilitating sanctions evasion. The legislation creates a novel framework where tariffs stack on top of existing duties while codifying Russia sanctions into statute...
GlobalInternational Law
Akin
Akin
Article

President Trump Directs Removal Of Canadian Products From Federal Procurement

On September 16, 2026, President Trump issued a presidential memorandum titled “Restoring Reciprocity in Government Procurement”, directing the Director of the Office of Management and Budget and the United States Trade Representative, in coordination with the Federal Acquisition Regulatory Council, to identify and take legally permitted steps to remove or restrict Canadian-origin items across the federal civil procurement system.
GlobalGovernment, Public Sector
Akin
Akin
Article

Major CIPA Reform Could Wipe Out Thousands Of Website Tracking Claims

California's Legislature has unanimously passed SB 690, a landmark reform that could eliminate thousands of pending class action lawsuits based on website tracking technologies under the California Invasion of Privacy Act. The bill removes the private right of action for pen register claims arising from routine web analytics tools, potentially reshaping the data privacy litigation landscape while companion bills simultaneously expand substantive privacy obligations.
United StatesPrivacy
Akin
Akin
Article

EU Finalizes Streamlined ESRS And New Voluntary Reporting Standard

The European Union’s (EU) revamped sustainability reporting framework is now final. On September 21, 2026, the revised European Sustainability Reporting Standards (ESRS) and a new Voluntary European Sustainability Reporting Standard (VS) were published in the Official Journal, marking yet another significant step toward more proportionate sustainability reporting in Europe. In addition to previously raising applicable financial thresholds triggering compliance under the Corporate Sustainability Reporting Directive (CSRD), the revised ESRS cut mandatory datapoints for in-scope companies (i.e., undertakings under CSRD) by more than 60% and total datapoints by more than 70%.
European UnionCorporate/Commercial Law
Akin
Akin
Article

Senate Unveils Bipartisan Comprehensive Permitting Reform Bill

On September 30, 2026, Senate Environment and Public Works (EPW) Committee Chair Shelley Moore Capito (R-WV), Ranking Member Sheldon Whitehouse (D-RI), Senate Energy and Natural Resources (ENR) Committee Chair Mike Lee (R-UT), and Ranking Member Martin Heinrich (D-NM) unveiled the Bipartisan American Affordability and Jobs Act of 2026 (BAAJA; S. 5653), a comprehensive permitting reform package aimed at accelerating approvals for energy, infrastructure, transmission, mining, manufacturing, and other major projects. The legislation represents the most significant bipartisan permitting reform effort in years and follows months of negotiations between Senate Republicans and Democrats.
United StatesEnergy and Natural Resources
Akin
Akin
Article

Preventing Workplace Sexual Harassment: A Transatlantic Comparison Of Employer Obligations In The US & UK

As prevention obligations expand across the UK, California, New York State, and New York City, employers face heightened duties to prevent workplace sexual harassment before it occurs. With the UK's new "all reasonable steps" standard taking effect in October 2026 and US jurisdictions lowering liability thresholds, how can multinational employers navigate these evolving transatlantic requirements?
GlobalEmployment and HR
Akin
Akin
Article

SEC Risk Alert Highlights Common Deficiencies In Investment Adviser Annual Compliance Reviews

The SEC's Division of Examinations has identified six critical areas where investment advisers commonly fall short in their annual compliance reviews, from timing failures to inadequate documentation and unimplemented corrective actions. Understanding these deficiencies is essential for advisers seeking to strengthen their compliance infrastructure and avoid examination risks.
United StatesFinance and Banking
Akin
Akin
Article

SEC Issues Guidance On Fair Value Measurement And Disclosure For Private Credit And Other Private Assets For Registrants And Others

The SEC Staff has issued new guidance addressing valuation challenges for private credit and other private assets held by public companies and registered investment companies. The statement emphasizes the need for robust valuation policies, market-based assumptions, and transparent disclosure practices as the private credit market continues to expand. Investment advisers managing private funds should carefully consider how these principles apply to their own valuation procedures and investor communications.
United StatesFinance and Banking
Akin
Akin