We all know what a “core” sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have to be aware of conduct that may still violate the law but is not necessarily in the “heartland” of misconduct. DOJ, OFAC and BIS are well aware of the broad reach of...
Matt Stankiewicz, Partner at The Volkov Law Group, rejoins us to discuss the DOJ’s cryptocurrency enforcement efforts. He can be reached at [email protected]. In early October, U.S. Department of Justice (“DOJ”) Deputy Attorney General Lisa Monaco announced the creation of the National Cryptocurrency Enforcement Team (“NCET”). The NCET will handle the Department’s investigations and enforcement actions relating to cryptocurrency and virtual assets, which has seen...
I respect prosecutors, most of them at least. I had the fortunate opportunity to work with a number of terrific prosecutors. Most are intelligent, hard working and committed to doing the right thing. I recognize that there are times when a prosecutor crosses the line, and for those prosecutors, I have no sympathy. Whatever punishment they receive is usually well deserved. But a very high...
