The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money transmission, cryptocurrency and cryptocurrency exchanges are at risk for exploitation by criminal actors, including those attempting to evade economic sanctions. Several attributes of cryptocurrencies that are usually touted in favor of the technology—pseudonymity, decentralization, digitalization—are now giving government officials, regulators, and lawmakers cause for concern in the sanctions climate. In response, leaders in the crypto community are voicing support of sanctions compliance, and citing aspects of the technology—traceability, immutability, visibility—in reassurance of it. As discussed below, there are several steps that crypto platforms can take to further efforts in blocking and detecting sanctions evasion activity on their platforms.
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Sarah Aberg
Sarah Aberg is special counsel in the White Collar Defense and Corporate Investigations Group in the firm's New York office.
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Five Keys to a Successful Compliance Risk Assessment
By Sarah Aberg & J. Scott Maberry on
Posted in FCPA
Corporate compliance programs are expected to be tailored to an organization’s unique risks. Most regulators (and most modern organizational compliance programs) prescribe risk-based compliance. But one thing is to prescribe; another is to execute properly.
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