On November 14, 2023, the SEC's Division of Enforcement announced its Enforcement Results for Fiscal Year 2023. Below are some key takeaways for fund managers.
Cryptocurrency firms subject to U.S. jurisdiction must take care to ensure that their platforms do not transact with sanctioned entities such as Tornado Cash, as OFAC sanctions violations are subject to a “strict liability” standard meaning no intent, knowledge, or reason to know that one is dealing with a sanctioned person is required for a violation to occur.
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"Fintech" refers generally to the financial services industry's emerging use of sophisticated software, including machine learning and artificial intelligence (AI), and other modern technologies.
On March 2, 2022, the U.S. Department of Justice announced the launch of Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the unprecedented sanctions.