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In today’s corporate environment, it is no longer enough to just have a compliance program on file. Proper and timely training, focus on high-risk roles, and working alongside your compliance team are critical.

Speaking at the Munich Cyber Security Conference on February 17, 2022, Deputy Attorney General Lisa O. Monaco announced that the U.S. Department of Justice (“DOJ”) plans to prioritize “cyber disruption,” foster international partnerships, and increase its investigative and deterrent capabilities to bolster its crypto-enforcement arsenal and to combat cyber threats.

Larry Dean Harmon, the founder and operator of Helix, a darknet-based cryptocurrency “mixer” or “tumbler,” recently admitted that Helix partnered with darknet marketplaces to provide bitcoin money laundering services for darknet market customers.

On June 24, 2021, UK law enforcement seized a record-setting £114 million (nearly $160 million) in cryptocurrency as part of an ongoing money laundering investigation.

The recent Criminal Antitrust Anti-Retaliation Act (CAARA), to be enforced by the Occupational Safety and Health Administration (“OSHA”), offers protection from retaliation for antitrust whistleblowers who come forward to report possible criminal violations internally or directly to government authorities.

Two weeks ago, the Department of Justice (“DOJ”) announced two significant enforcement actions and shut down NetWalker and Emotet, powerful tools that had been used by alleged criminal networks engaging in widespread ransomware extortion schemes.

Update: On January 1, 2021, the Senate voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (“NDAA”).

The Financial Crimes Enforcement Network (“FinCEN”) recently hit the founder and primary operator of both Helix and Coin Ninja with a $60 million civil monetary penalty.

On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and plans for increasing scrutiny into the use of cryptocurrency, following the Task Force’s inception in 2018.

Recently, BuzzFeed News and the International Consortium of Investigative Journalists (“ICIJ”) reported on a 16-months’ long investigation into a trove of explosive documents apparently leaked from the U.S. Financial Crimes Enforcement Network (“FinCEN”).

The Financial Crimes Enforcement Network (“FinCEN”) is asking for feedback on potential regulatory amendments aimed at ensuring that anti-money laundering (“AML”) programs are “effective and reasonably designed.”

In a significant move toward more transparency, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released new guidance (the “Guidance”) on August 18, 2020, setting forth its enforcement approach and detailing the factors that FinCEN will consider when evaluating matters involving potential violations of the Bank Secrecy Act (“BSA”).