OFAC Continues To Demonstrate Greater Interest In Cryptocurrency Regulation And Enforcement

With the widespread arrival of Initial Coin Offerings (“ICOs”) over the last several years,¹ U.S. authorities have made deliberate progress toward keeping pace with the fast-growing crypto industry.² The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has arguably been slower to action than either the U.S. Department of Justice (“DOJ”) or the U.S. Securities and Exchange Commission (“SEC”), both of which have taken an aggressive approach resulting in high-dollar settlements.³ With that said, however, OFAC has more recently taken steps that suggest cryptocurrency regulation and enforcement will be a high-priority item moving forward.

I.OFAC’s Historical Regulation of Cryptocurrency