International Developments

OFAC on Bitcoin—Learning Before Actively Regulating

Before a government agency issues regulations implementing a new law—or applies existing regulations to a new technology—it has to do some groundwork.  The agency will interpret its authorizing legislation and executive orders before gathering evidence to support the exercise of its rulemaking and enforcement authorities.  Some agencies are subject to…

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European Securities Regulator Calls for Information Concerning Virtual Currency

On April 22, 2015, the European Securities and Markets Authority (“ESMA”) – the European Union’s (“EU”) securities watchdog agency – issued a formal call for evidence regarding investments using virtual currency or distributed ledger technology. ESMA is an independent EU authority responsible for safeguarding the stability, integrity, transparency, and efficiency…

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Lessons From Mt. Gox Bankruptcy

MtGox Co., Ltd., once the world’s largest Bitcoin exchange company, is insolvent, bankrupt, and now history.  This bankruptcy (which I discussed yesterday) offers lessons to cryptocurrency startups. Mt. Gox’s fundamental lack of professionalism has become painfully clear since it filed for bankruptcy.  According to a Wired expose last year, former…

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OFAC Announces Settlement with PayPal for Apparent Sanctions Violations

On March 25, 2015, the Department of the Treasury’s Office of Foreign Assets Controls (OFAC) announced a settlement with electronic funds transfer giant PayPal, Inc. At issue were almost 500 transactions totaling approximately $44,000 in violation of various U.S. sanctions programs, including for Iran, Cuba, Sudan, proliferation of weapons of…

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