In the wake of the invasion of Ukraine, we have seen a wave of U.S. and European sanctions targeting Russia. Key financial institutions, the Russian Central bank, elites, key sectors such as energy, mining, telecommunications, and transportation have all been hit. Will Russia turn to cryptocurrency to evade sanctions?
In this TRM Talks, Ari Redbord, Head of Legal and Government Affairs at TRM, is joined by Carole House, Director for Cybersecurity and Secure Digital Innovation for the White House National Security Council (NSC) and Todd Conklin, Counselor to the Deputy Secretary of the U.S. Treasury, to discuss Russia sanctions, the possibility of sanctioned Russian actors using crypto to evade sanctions, and how Treasury, the White House, and the U.S. government intend to enforce escalating sanctions on Russia.

A Decentralized Autonomous Organization (DAO) is a community-governed entity with no central authority. Imagine a corporation — made up of a network of individuals with a common interest — where the governance rules and decision-making are executed by software programs and the community shares a bank account funded with cryptocurrency for the purpose of fulfilling their shared vision. We have seen DAOs form to bid on an original copy of the U.S. Constitution, to buy an NBA team, and to facilitate financial services.

In this month’s TRM Talk, we’re joined by leading experts to unpack the Tao of a DAO: Aaron Wright, Professor at Cardozo School of Law and co-founder and CEO of Tribute Labs; Graham Novak, Partner at 28th Street Ventures who launched ConstitutionDAO; and Patrick South, Director of Business Development at TRM Labs.

Tune in to learn: 

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. Learn more about our mission to build a safer financial system for billions of people here: https://www.trmlabs.com/about

In April 2021, Wyoming Gov. Mark Gordon signed the state’s DAO-focused Bill 38 into law, allowing Wyoming to recognize DAOs as limited liability corporations (LLCs). The law went into effect in July 2021. LLCs are hybrid entities that combine the characteristics of a corporation with those of a partnership or sole proprietorship.

As explained to Coindesk by TRM Talks alum, Wyoming Sen. Chris Rothfuss, the bill makes the process of a DAO becoming an LLC easier and cheaper. “A lot of our work in Wyoming on blockchain and fintech governance has been focused on providing legal clarity where ambiguity exists before the court needs to decisively weigh in.”

Check out this primer on DAOs and hear from DAO legal expert Matthew Kaufman of Wyoming law firm Hathaway & Kunz, LLP. Matt was instrumental in his work related to Wyoming’s first-in-the-nation cryptocurrency framework, as discussed on TRM Talks Wyoming, and the state’s DAO law. Matt joins TRM Talks to share legal insights on what the DAO law does, why it matters, and how DAOs, and entities that engage with DAOs, should think about their regulatory requirements.

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. Learn more about our mission to build a safer financial system for billions of people here: https://www.trmlabs.com/about

Over the last few years, we have seen global regulators — from Singapore to Hong Kong, the U.S. to the U.K — zero in on crypto transactions. And much of that discussion has centered around one regulation: the Travel Rule.  

While the Travel Rule has been discussed and debated, we are now hearing a louder drumbeat for implementation. What does that mean for crypto compliance and how should firms think about approaching implementation?  Watch this TRM Talk to hear a panel of compliance experts discuss:  

If you don't want to get called for traveling, tune in and read more about the Travel Rule here. 

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. 

Learn more about our mission to build a safer financial system for billions of people here: https://www.trmlabs.com/about

The U.S. Department of Justice (DOJ) recently announced that it has arrested and charged two individuals with laundering funds associated with the 2016 hack of cryptocurrency exchange Bitfinex. According to charges filed in federal court, the hacker stole 119,754 thousand BTC, which at the time of the breach, was worth around $71 million. Today that bitcoin is worth around $4.5 billion. The Bitfinex hack seizure was the largest seizure of funds in the history of the United States. Over the ensuing years, according to a statement of facts, the defendants moved the funds through an on-chain labyrinth of laundering techniques including the use of fictitious identities, automated transactions, the use of a variety of exchanges and darknet markets, mixing services, privacy coins and chain hopping. The defendants are charged with conspiracy to commit money laundering, which carries a maximum sentence of 20 years in prison, and conspiracy to defraud the United States, which carries a maximum sentence of five years in prison.

How did law enforcement build this case across years and blockchains? How does an on chain investigation using blockchain analytics tools lead to arrests? How will this case now proceed? What do these charges mean and what are the defendants likely to face over the coming weeks and months? What impact does this case have on the cryptocurrency space? For the answers to these questions, TRM Talks to former United States Attorney for the District of Columbia — the office that is prosecuting the Bitfinex case — Jessie K. Liu, now a partner at Skadden Arps, Former IRS-CI special agents Tigran Gambaryan and Matthew Price, both now at Binance leading intelligence and investigations respectively.

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. Read Federal judge issues opinion on the reliability of blockchain analytics in Bitfinex case: https://www.dcd.uscourts.gov/file/20sc3310-opinionpdf

Non-Fungible Tokens (NFTs) — unique crypto assets hashed to a blockchain — have taken the world by storm. From Cryptopunks to NBA Top Shot, Beeple to Bored Apes, NFTs have impacted sports, pop culture, gaming and art. 

There are discussions of NFTs in healthcare, real estate, record keeping, and myriad other use cases where certification of authenticity is critical. How can businesses get involved safely?  

Watch this episode of TRM Talks to hear answers to the big questions surrounding NFTs from Jennifer Lee, Head of Compliance at Anchorage Digital (which recently helped Visa with its historic purchase of a Cryptopunk); Cody Berlin, Chief Technology Officer at NFT marketplace Autograph, and Joe McGill, former U.S. Secret Service Agent and resident expert on illicit finance risks for NFTs at TRM Labs. In this session, we cover:  

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. 

See how TRM helps organizations conduct NFT risk assessments here: https://www.trmlabs.com/nft

On October 28, 2021, the Financial Action Task Force (FATF) released its Updated Guidance For A Risk Based Approach For Virtual Assets and Virtual Asset Providers (guidance or final guidance). The guidance hit on some of the hottest topics in crypto including DeFi, NFTs, unhosted wallets, stablecoins and the travel rule.  

Here are some takeaways:  

Check out TRM's full coverage of FATF's guidance here: https://www.trmlabs.com/post/fatf- provides-final-guidance  

Joining TRM Talks to discuss the guidance and get clarification on key issues are the chairs of FATF's Virtual Assets Contact Group (VACG), Habuchi Takahide of Japan's Financial Services Agency and Jon Fishman of the U.S. Treasury. 

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. Learn more about how we're building a safer financial system for billions of people here: https://www.trmlabs.com/about

Todd Conklin, Counselor to the Deputy Secretary, joined a special edition of TRM Talks to announce and explain the action: "New industry-specific guidance outlines sanctions compliance best practices tailored to the unique risks posed in this dynamic space, while new data from [FinCEN] shows the increasing threat ransomware posed to the U.S financial sector, businesses, and the public during the first half of 2021."  

In the wake of last month's OFAC designation of non-compliant nested crypto exchange SUEX, the administration has taken a series of measures to coordinate across the federal government and with the private sector on the issue of ransomware. Last week, the U.S. Department of Justice announced the creation of a National Cryptocurrency Enforcement Team (NCET) comprised of prosecutors focused on combatting the use of crypto for illicit finance. This week the White House issued a fact sheet on ransomware which focused on disrupting ransomware actors and hardening cyber defenses. The fact sheet also addressed the importance of mitigating the risk of illicit activity by enforcing anti-money laundering compliance in the crypto space.  

Today's Treasury action, which includes the release of new Ransomware Trends in Bank Secrecy Act data from FinCEN, was the latest move. FinCEN’s analysis of ransomware-related SARs highlights average ransomware payment amounts, prevalent ransomware variants, and prominent ransomware money laundering typologies. 

See the analysis and access resource links here: https://www.trmlabs.com/post/watch-the-interview-treasury-comments-on-release-of-ransomware-related-data-and-guidance 

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. Learn more about our mission to build a safer financial system for billions of people here: https://www.trmlabs.com/about

For crypto exchanges and other digital asset service providers, the nuts and bolts of a robust compliance program are many — from FinCEN to FATF, SARS to subpoenas, transaction monitoring to the travel rule. 

As legislators and regulators around the globe attempt to bring legal clarity to crypto, compliance teams are meanwhile tasked with understanding and applying current regulatory frameworks to their businesses, and more broadly, with managing financial crime risk as it takes new and different shapes in the cryptoverse.   

In this edition of TRM Talks, legal and compliance experts in the crypto space discuss the building blocks of a strong crypto compliance program, plus challenges and best practices to consider, including:  

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. 

Learn more about our mission to build a safer financial system for billions of people here: https://www.trmlabs.com/about

Treasury officials offer additional commentary on their first crypto exchange action and advisory in an exclusive interview with TRM Labs.  

U.S. Treasury's Office of Foreign Assets Control (OFAC) took its first-ever action against a cryptocurrency exchange, SUEX.io, a concierge cryptocurrency exchanger incorporated in Czechia but operating in Russia. This action comes as the United States attempts to tackle the scourge of ransomware attacks and harden cyber defenses against cybercriminals and rogue nation-state actors.   

In the view of Treasury, SUEX fills an essential niche in the ecosystem of under-regulated exchanges that, either through willful ignorance or witting cooperation, facilitate the conversion of illicit crypto ransoms into real-world currency.  

SUEX also operated as a so-called "nested" or "parasite" exchange, meaning SUEX did not directly custody of its clients' crypto. Instead, it fed off the infrastructure of a large, global cryptocurrency exchange to conduct its transactions. Nested exchanges often take advantage of the greater liquidity and lower transaction costs of big, multinational exchanges while presenting customers with a custom-made interface obscuring the connection to the larger service. Using this relationship with a large exchange, and access to cash from unknown sources, SUEX was able to convert the illicit monies of its clients to physical cash at an alarming scale. 

See TRM's deep-dive investigation on Suex here: https://www.trmlabs.com/post/behind-suex-io-the-first-sanctioned-cryptocurrency-exchange 

Todd Conklin, Counselor to the Deputy Secretary of the Treasury, highlighted the risk associated with nested exchanges when discussing the action with us this morning in a special edition of TRM Talks. 

Read more about the advisory here: https://www.trmlabs.com/post/ofac-takes-first-action-against-cryptocurrency-exchange-and-issues-updated-ransomware-advisory 

This podcast is hosted by TRM Labs, a blockchain analytics company. We work with crypto businesses, financial institutions and government agencies to monitor, detect and investigate fraud and financial crime in crypto. Learn more about our mission to build a safer financial system for billions of people here: https://www.trmlabs.com/about