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Office of Foreign Assets Control (“OFAC”) Sanctions Compliance Guidance for the Virtual Currency Industry

In mid-October 2021, OFAC issued sanctions compliance guidance (the “OFAC Guidance”) for the virtual currency industry, including tech companies, exchanges, administrators, miners, crypto wallet providers, and even users. OFAC issued the guidance to help the virtual currency industry mitigate the risks of transacting cryptocurrencies with a sanctioned country, entity, or individual. OFAC is the...
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Lawmakers and Regulators Recognize Crypto and Blockchain Present Unique Problems for Traditional Enforcement Mechanisms

Congressional Democrats Seek Increased Oversight Into Crypto Matters Following Ransomware Attacks A group of Democratic senators and congressmen are calling on the Department of Justice, the State Department, the Department of the Treasury, and Homeland Security to beef up efforts to protect against the recent wave of ransomware attacks. The group, comprised of senators...
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DOJ Announces Creation of Cryptocurrency Enforcement Team

Posted on October 8, 2021
On October 6, 2021, the Department of Justice (“DOJ”) announced the creation of the National Cryptocurrency Enforcement Team (“NCET”) to investigate and prosecute criminal misuses of cryptocurrency. NCET’s particular focus will be on crimes committed by virtual currency exchanges, mixing and tumbling services, and money laundering infrastructure actors, to include the tracing and recovery...
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Civil Cyber-Fraud Initiative to Hold Government Contractors Responsible for Cybersecurity

On October 6, 2021, the Department of Justice (DoJ) announced the Civil Cyber-Fraud Initiative (the “Initiative”) to combat cyber threats, specifically to sensitive information and critical systems of the United States Government (USG). In launching the Initiative, Deputy Attorney General Lisa O. Monaco made clear that a primary focus of the Initiative is to...
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FAR Council, CAAC, and DoD Release COVID-19 Guidance

The FAR Council, the Department of Defense (“DoD”), and the Civilian Agency Acquisition Council (“CAAC”) have released guidance for federal government contractors on COVID-19 safeguards required by President Biden’s September 9, 2021, Executive Order 14042 (the “Order”) and the Safer Federal Workforce Task Force’s September 24, 2021, Guidance, COVID-19 Workplace Safety: Guidance for Federal...
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Civilian Agency Acquisition Council (“CAAC”) Memorandum: Class Deviation Regarding Executive Order 14042 Ensuring Adequate COVID Safety Protocols for Federal Contractors

On September 30, 2021, the Civilian Agency Acquisition Council (“CAAC”) released a memorandum authorizing all civilian United States government agencies to issue a class deviation to implement Executive Order 14042, “Ensuring Adequate COVID Safety Protocols for Federal Contractors.” Attached to the CAAC memo is a FAR Deviation Clause (the “Clause”) that CAAC states “is...
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