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ARTICLE · 03 NOVEMBER 2021

OFAC Issues Sanctions Compliance Guidance For Virtual Currency Industry

Cooley LLP
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The US Department of the Treasury's Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry.

United StatesInternational Law
Adam Fleisher
Adam Fleisher
Jonathan A. Gordon
Jonathan A. Gordon
Kevin King
Kevin King
Sarah Oliai
Sarah Oliai
Obrea Poindexter
Obrea Poindexter
Rebecca Ross
Rebecca Ross
Sean Ruff
Sean Ruff
Karen Tsai
Karen Tsai
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The US Department of the Treasury's Office of Foreign Assets Control (OFAC) recently issued Sanctions Compliance Guidance for the Virtual Currency Industry. The guidance published on October 15, 2021, outlines OFAC's expectations for virtual currency companies and other industry participants. It also provides a summary of OFAC resources and actions addressing virtual currency, including previously issued answers to frequently asked questions (FAQs).1

In emphasizing the importance of implementing a tailored, risk-based sanctions compliance program, OFAC states that new and emerging companies (e.g., technology companies, exchangers, administrators, miners and wallet providers) sometimes do not implement sanctions policies and procedures until "months, or even years, after commencing operations." The guidance notes that OFAC sanctions compliance obligations are the same for all industries and that OFAC regulations apply equally to transactions involving virtual or fiat

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