AGG partners and Emerging Technology team members, Allison Raley and Paula Nagarajan, authored a Law360 article analyzing the implications of the DOJ’s April policy update — commonly referred to as the Blanche memo — which narrows the agency’s digital asset enforcement focus to investor fraud, terrorism financing, and narcotics-linked transactions.
The article explores how this shift away from speculative theories may ease enforcement risk concerns for sponsor banks and fintechs, while reinforcing the need for strong compliance and governance practices.
Allison and Paula, with insights from Aprio’s Haley Beatty and Cristina Hazelwood, offer practical guidance for counsel advising nontraditional financial companies, including segmenting financial activities, aligning anti-money laundering controls with DOJ priorities, clarifying licensing positions, and preparing for increased regulatory engagement.
To read the full article, please click here (subscription required).
- Allison E. Raley
Partner
- Paula M. Nagarajan
Partner
