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?