For Crowell & Moring LLP’s next event in our series “Emerging Issues in Sanctions, AML, and Everything in Between in the Time of COVID-19,” our Global Head of Blockchain & Digital Assets, Michelle Gitlitz, will moderate a discussion on the AML & Sanctions risks that digital assets companies are currently grappling with. Topics will include:

How Do AML and Sanctions Laws Apply to Digital Assets? What are the Key Regulatory Risks?

• What kinds of digital assets businesses are subject to AML regulation?
• What kind of AML obligations do regulated entities have?
• How do sanctions apply to digital assets transactions, assets, and wallets?
• What sanctions obligations do digital assets businesses have?

Potential Areas for AML and Sanctions Enforcement for Digital Assets in 2020

• Unregistered money transmitter
• Inadequate AML programs and failure to file SARs
• The Funds Transfer and Travel Rules
• OFAC’s interest in digital assets companies
• Expert advice on virtual currency to sanctioned parties

The potential Impact of COVID-19

• Is there an increase in the use of cryptocurrency by sanctioned persons, money launderers and fraudsters during COVID-19?