Regulation

Crypto evasion: The new frontier of sanctions enforcement

Issue 25.
July/August 2022

Author
B. Stephanie SiegmannIsha Kumar
+ About author

B. Stephanie Siegmann is a Partner at the law firm of Hinckley, Allen & Snyder LLP, and Chair of its International Trade and Global Security Practice. Prior to joining Hinckley Allen, Stephanie served as the National Security Chief at the U.S. Attorney’s Office for the District of Massachusetts and worked as both a federal and Navy JAG prosecutor for more than 22 years. www.hinckleyallen.com

Isha Kumar is a student at Boston University School of Law and is working as a summer associate at Hinckley, Allen & Snyder LLP. www.hinckleyallen.com

The United States Department of Justice (“DOJ”) recently brought criminal charges in a first-of-its-kind prosecution against a US citizen for allegedly transmitting more than $10 million in bitcoin to a sanctioned country to evade US law.

On 13 May 2022, US Magistrate Judge Zia Faruqui, a former national security prosecutor, released an unusual opinion explaining why he had approved the first cryptocurrency sanctions complaint, which remains under seal.1 As a result, the opinion did not dis...

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