Blockchain Legal Resource

What Happened:

On March 8, 2022, President Biden issued an Executive Order (the “March 8 Executive Order”)¹ prohibiting the importation of Russian-origin oil, liquified natural gas (“LNG”), and coal into the United States and prohibiting US persons from making new investments in Russia’s energy sector.  The March 8 Executive Order also prohibits US persons from providing any approval, financing, facilitation, or guarantee to a foreign person seeking to import Russian-origin oil into the United States or make new investments in Russia’s energy sector.  The March 8 Executive Order follows on a series of significant US sanctions actions against Russia in recent weeks.  The US Department of Justice and Treasury Department also announced additional efforts and guidance intended to emphasize US sanctions efforts and to provide guidance on detecting and preventing efforts by blocked persons to evade sanctions, including through the use of cryptocurrency.  On March 9, 2022, President Biden issued an Executive Order (the “Executive Order on Digital Assets”) directing US government agencies to study and report on cryptocurrencies and other digital assets and consider, among other things, the use of digital assets to circumvent US sanctions.²

A series of recent statements by key financial regulators and US senators once again bring cryptocurrency regulation into the spotlight. In this post, we summarize several recent developments.

What Happened:

On February 28, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued further sanctions on Russia’s Central Bank, National Wealth Fund, and Ministry of Finance, and announced regulations to implement Executive Order 14024 under the Russia Harmful Foreign Activities Sanctions Program. On February 24, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an immediate final rule implementing sanctions under the Export Administration Regulations (“EAR”).¹