The U.S. Department of the Treasury's Office of Foreign
Assets Control ("OFAC") published Sanctions
Compliance Guidance for the Virtual Currency Industry
("Guidance")1 on its official website
on October 15, 2021, by expressing that the Guidance is published
as a resource to help members of the virtual currency industry
navigate and comply with OFAC sanctions, and to ensure OFAC's
commitment to engage with the virtual currency industry to promote
an understanding of, and compliance with, sanctions requirements.
OFAC also expressed in its announcement that it has updated its
Frequently Asked Questions 559 and 646 which are associated with
the topic.
The Guidance explains that OFAC regulations apply to all U.S.
persons, as well as all entities organized under the laws of the
United States or any jurisdiction within the United States,
including any foreign branches of those entities. Accordingly, the
Guidance notes that anyone engaging in virtual currency activities
in