- Crypto vaults exist on a broad spectrum, from fully automated smart contract allocations to discretionarily managed
Crypto Vaults: US Regulatory Considerations
Banking Regulators Propose Customer Identification Rules Under the GENIUS Act
- Permitted payment stablecoin issuers would be required to establish and maintain written, risk-based customer identification programs tailored to their size and business models.
- The proposed requirements would include reasonable procedures for verifying customer identity, maintaining verification records, checking customers against relevant government
Fifth Circuit Overturns OFAC Sanctions Against Crypto Mixer Tornado Cash
The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes.
By Eric Volkman, Jenny Cieplak, Stephen P. Wink, and Deric Behar
On November 26, 2024, a three-judge panel of the US Court of Appeals for the Fifth Circuit reversed a Texas District Court decision and overturned the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions designations against certain smart contracts
OFAC Sanctions Decentralized Virtual Currency “Mixer”
The US Treasury opens a Pandora’s box of legal issues as it targets a decentralized finance protocol used for both licit and illicit means.
By Eric Volkman and Deric Behar
On August 8, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions against decentralized virtual currency “mixer” Tornado Cash (and 44 associated USDC and ETH addresses) — the first action of its kind against a decentralized finance (DeFi) protocol.
Mixers (or “blenders”) are centralized