ICYMI – The US Department of Justice Releases its Cryptocurrency Enforcement Framework
TLDR – The US DOJ and the Office of the Attorney General released an 83-page report describing the US Government’s overall vision for a Cryptocurrency Enforcement Framework. Initial reaction was mixed, with privacy advocates and the libertarian-minded among the cryptocurrency community expressing their concerns.
The Framework is a great primer on various cryptocurrency technologies and advancements as seen through a public safety and national security context. There are a number of case studies that illustrate law enforcement concerns with respect to cryptoassets and represent a range of worst-case scenarios in the illicit applications of crypto.
In the document’s introduction, the Chair of the Attorney General’s Cyber-Digital Task Force, Sujit Raman identifies a significant set of challenges facing law enforcement and regulators and tacitly acknowledges the game of catch up governments are in when it comes to the cryptoasset ecosystem.
For compliance practitioners, there’s a section that covers the potential risks enterprises face as enumerated through identified criminal code authorities. This should be studied in the context of the recent OFAC and FinCEN advisories regarding AML and sanctions risk exposure when making ransomware payments to potentially sanctioned entities for an overall view into the US Government’s approach.
Additionally, the report lays out the various regulatory authorities and organizations with which the DOJ coordinates its law enforcement efforts including with international organizations such as the FATF (Financial Action Task Force).
Overall, it is a great read and addition to a compliance and investigations practitioner’s library as much for its reference section as it is for the embodied perspective.
Report of the Attorney General’s Cyber Digital Task Force – Cryptocurrency Enforcement Framework
https://www.justice.gov/ag/page/file/1326061/download
ZDNet had a good summary article, link below:
US unveils enforcement framework to combat terrorist, criminal cryptocurrency activities
Coindesk.com also had a good summary article, link below:
The DOJ’s ‘Crypto Enforcement Framework’ Argues Against Privacy Tools and for International Regulation
https://www.coindesk.com/crypto-enforcement-framework?amp=1&__twitter_impression=true
