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ARTICLE · 08 MAY 2018

NFA Reminds Members To Comply With OFAC Virtual Currency Obligations

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NFA advised futures commission merchants and introducing brokers to ensure that their anti-money laundering programs meet requirements set by the U.S. Treasury's Office of Foreign Assets Control...

United StatesTechnology
Christian Larson
Christian Larson
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The National Futures Association ("NFA") advised futures commission merchants and introducing brokers to ensure that their anti-money laundering programs meet requirements set by the U.S. Treasury's Office of Foreign Assets Control ("OFAC") with respect to virtual currency transactions.

The NFA referenced five FAQs that OFAC issued in March that provide guidance about sanctions obligations involving virtual currency. According to the FAQs, OFAC may add digital currency addresses connected to a person on OFAC's Specially Designated Nationals and Blocked Persons ("SND") list.

Commentary / ChristianLarson

Notable in the OFAC FAQs is the statement that "OFAC's digital currency address listings are not likely to be exhaustive." OFAC expects U.S. persons to block virtual currency they believe is owned by or associated with an SDN, even if the virtual currency is transferred to or from a digital currency address that OFAC has not included on the SDN list.

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