OFAC's Eye On Virtual Currencies – Cryptocurrency Regulation And Enforcement Updates

There is no doubt that United States regulators and government agencies have been paying close attention to the virtual currency industry over the past several years. In the past few months, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued two publications highlighting its growing focus on the virtual currency industry. Specifically, on September 21, 2021, OFAC updated its  Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments, and just a few weeks later, on October 15, 2021, issued a brochure on  Sanctions Compliance Guidance for the Virtual Currency Industry. The Treasury Department also recently commented on the digital asset space in its  2021 Sanctions Review. The Review discussed the possibility that typical sanctions may not be as effective in combating illegal transactions in the virtual currency space. In order to increase efficacy, the Treasury recognized that it should “invest in deepening its