NY Department of Financial Services Slaps $30 Million Fine on Robinhood’s Crypto Platform for Lax Anti-Money Laundering Controls

On August 1, 2022, the New York Department of Financial Services (“DFS” or the “Department”) secured its first enforcement win against a cryptocurrency platform, Robinhood’s crypto trading arm Robinhood Crypto, LLC.

Robinhood Crypto is a wholly-owned subsidiary of Robinhood Markets, Inc. (RHM).  RHM allows users to trade stocks on a commission-free basis through its broker-dealer subsidiary, Robinhood Financial, LLC (RHF).  Robinhood Crypto allows RHF customers to trade cryptocurrencies using customers’ U.S.… More

SEC and DOJ Bring First-Ever Crypto Insider Trading Actions

Key Takeaways:

  • The U.S. Securities and Exchange Commission (“SEC”) and U.S. Department of Justice (“DOJ”) have brought the first-ever insider trading actions involving cryptocurrency against a former manager of Coinbase, one of the largest U.S. crypto asset trading platforms, and two tippees for sharing or trading upon confidential information relating to the planned listing of various cryptocurrencies on Coinbase.
  • The SEC’s securities fraud charges are based on its longstanding position that certain cryptocurrencies are investment contracts and therefore “securities” subject to the SEC’s jurisdiction.…
  • More

Russia Sanctions and Export Controls Update – July 6, 2022

Key Takeaways:

  • OFAC imposes restrictions on the importation of gold from the Russian Federation
  • OFAC and the U.S. Department of State impose new sanctions on Russian entities and individuals with a focus on the Russian defense and aerospace industries
  • The U.S. Department of Commerce’s Bureau of Industry and Security imposes additional export controls on entities identified as attempting to evade U.S. export controls and sanctions on Russia and issues a joint alert with FinCEN warning U.S.…
  • More

ESG Enforcement Actions Underscore SEC Focus on Public Company and Investment Adviser Disclosure

Key Takeaways:

  • The U.S. Securities and Exchange Commission’s (SEC’s) Climate and ESG (Environmental, Social, and Governance)Task Force has brought its first two enforcement actions for allegedly misleading ESG-related disclosures by a public company and an investment adviser, respectively.
  • The actions reflect the close and continuing focus on ESG by the SEC’s Division of Enforcement (Enforcement); more such actions are virtually certain to follow.
  • These cases also underscore the importance for issuers and advisers of mitigating the risk of ESG-related disclosure violations through robust internal controls and careful vetting of public statements about ESG impacts and investments.…
  • More

SEC’s Expansion of Crypto Assets and Cyber Unit Signals Increased Enforcement Ahead

Key Takeaways:

  • The U.S. Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement) announced that it will nearly double the size of its Crypto Assets and Cyber Unit, making the Unit one of the largest within Enforcement.
  • The decision reflects the SEC’s increasing prioritization of cryptocurrency and cybersecurity enforcement.
  • Issuers of digital assets, crypto exchanges and lending platforms, and other industry participants should expect more frequent investigations and enforcement actions.…
  • More

Russia and Belarus Sanctions and Export Controls Update – June 14, 2022

Key Takeaways:

US Actions:

  • The Bureau of Industry and Security (“BIS”) imposes new restrictions on the export of certain industrial EAR99 items to Russia
  • OFAC extends expiration date for general licenses related to administrative transactions and issues general license authorizing the processing of pension payments to U.S. persons by Russian financial institutions
  • OFAC adds Russian government officials, oligarchs, and mining companies to the SDN List,…
  • More

Russia and Belarus Sanctions and Export Controls Update – May 10, 2022

Key Takeaways:

  • The U.S. restricts the provision of accounting, trust and corporate formation, and management consulting services to Russia
  • OFAC publishes general license authorizing certain IP-transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations
  • Three Russian state-run media television companies are added to the SDN List, along with a Russian state-owned bank and a state-controlled defense company
  • BIS implements stricter export controls – only EAR99 items (with some limited exceptions) are now eligible for export from the U.S.…
  • More

Russia Sanctions Update – April 11, 2022

Key Takeaways:

  • U.S. sanctions major Russian state-owned enterprises Alrosa (diamonds) and United Shipbuilding Corporation (defense sector)
  • OFAC publishes new Russia-related general licenses, including a license authorizing certain transactions related to telecommunications
  • “Fifth Wave” EU sanctions package restricts trade with Russia and imposes sanctions on 217 individuals and 18 entities


I.    U.S. Actions

Following increased sanctions on Russian banks and a new Executive Order banning investment in the Russian Federation (reported by Foley Hoag here),… More

Russia Sanctions Update – April 7, 2022

Key Takeaways:

  • New Executive Order prohibits all new investment by U.S. persons in Russia
  • U.S. imposes full asset freezing sanctions on Alfa-Bank and Sberbank, along with more Russian government officials and their family members, including the daughters of Russian President Vladimir Putin
  • Sanctions target Russian cybercrime and ransomware


I.    New Executive Order Bans U.S. Investment in Russia

On April 6,… More

Russia Sanctions Update – March 28, 2022

Key Takeaways:

  • U.S. imposes sanctions on Duma members, board members and executives of sanctioned Russian banks, and defense companies
  • UK sanctions 65 individuals and entities, focusing on Russian oligarchs, financial institutions, and senior executives of state-owned enterprises
  • OFAC issues new FAQ clarifying that gold transactions fall within the scope of existing Russia-related sanctions


U.S. Sanctions

The U.S.… More