On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a blockchain-based technology used to enable transaction anonymity) accused of facilitating money laundering.Continue Reading Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On August 21, a group of trade organizations filed an amicus brief in support of a motion to dismiss filed by a subprime auto lender that is the target of a joint enforcement action brought by the CFPB and the New York State Office of the Attorney General in the Southern District of New York. The underlying complaint alleges that the auto lender misrepresented costs in loan agreements and tricked customers into high-cost loans on used cars in violation of the CFPA and New York usury limits (see previous blog post here). In particular, the complaint alleges that: (1) the auto lender’s business model allegedly incentivizes vehicle dealers to inflate vehicle prices so that the true finance charges in the retail installment contracts that dealers originate are hidden from consumers; and (2) the lender fails to assess consumers’ ability to pay prior to extending credit. Continue Reading Amicus Brief Argues CFPB Overreached in Enforcement Action Against Auto Lender