Robert A. Schwinger Among the conclusions offered in “Cryptocurrency Enforcement Framework” issued by the Department of Justice this past fall (see generally R. Schwinger, “Blockchain Law: DOJ’s ‘Cryptocurrency Enforcement Framework’,” NYLJ (Jan. 15, 2021)) was the ominous warning that “cryptocurrency presents a troubling new opportunity for individuals and rogue states to avoid international sanctions and to undermine traditional financial markets, thereby harming the interests of the United States and its allies.” A spate of recent government enforcement action shows that the United States is not hesitating to tackle cryptocurrency activity being used to try to circumvent the prohibitions of U.S. economic sanctions.
