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ARTICLE · 15 APRIL 2024

OFAC Sanctions Compliance Guidance For Virtual Currency

Lewis Brisbois Bisgaard & Smith LLP
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OFAC on October 15 issued its Sanctions Compliance Guidance for Virtual Currency, which provides that sanctions compliance obligations apply to transactions utilizing virtual currencies just as they do for dealings involving traditional currencies.

United StatesInternational Law
Ryan Whitney
Ryan Whitney
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Nashville, Tenn. (April 9, 2024) - The Office of Foreign Asset Control (OFAC) on October 15 issued its Sanctions Compliance Guidance for Virtual Currency (the "Guidance"), which provides that sanctions compliance obligations apply to transactions utilizing virtual currencies just as they do for dealings involving traditional currencies.

OFAC Sanctions Requirements

OFAC sanctions impose restrictions on financial or trade-related activities or the blocking of assets with a specific country, government, region, or individual. OFAC maintains list-based sanctions that publicly document individuals and entities for whom assets blocking is required or for whom financial/trade related activities are prohibited. The most common of these lists are the Specially Designated Nationals and Blocked Persons List ("SDN List") and the Consolidated Sanctions List.

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