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ARTICLE · 20 OCTOBER 2021

OFAC Issues Sanctions Guidance For The Virtual Currency Industry

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OFAC highlighted that sanctioned persons are drawn to virtual currency, both to perpetrate malign activity and to evade U.S. sanctions.

United StatesFinance and Banking

OFAC issued sanctions compliance guidance for participants in the virtual currency industry, including technology companies, exchangers, administrators, miners, wallet providers and traditional financial institutions.

In the guidance, OFAC provided both general information as to its sanctions programs and specific guidance as to the implementation of an effective sanctions compliance program for virtual currency industry participants. In updated FAQ 559, OFAC defined "digital currency," "digital currency wallet," "digital currency address" and "virtual currency," and in FAQ 646, OFAC provided details on the blocking of virtual currency pursuant to U.S. sanctions, including applicable reporting requirements.

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