The complex techniques some individuals and organizations employ to avoid sanctions regulations issued by the Office of Foreign Assets Control (OFAC) often make headlines. Although criminals intentionally evade sanctions, financial institutions (FIs) may unintentionally facilitate sanctions evasion—resulting in not only financial and reputational risk, but...
Virtual Currency Investigations: A Primer for BSA and Compliance Professionals

Anti-money laundering (AML) investigations involving virtual currency are problematic for investigators. This emerging asset class is expanding at an alarming rate. The regulatory environment is unsettled, dynamic and evolving. The development of investigative tools to address this emerging challenge has decreased significantly. Tracing payments—to...