Virtually Consistent

OFAC Guidance for the Virtual Currency Industry

On October 15, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued its first sanctions compliance guidance for the virtual currency industry. The guidance highlights the Treasury Department’s increased focus on virtual currencies and ransomware, both of which had been highlighted in the Financial Crimes Enforcement Network’s (FinCEN) Anti-Money Laundering and Countering the Financing of Terrorism National Priorities in June. Both OFAC and FinCEN published ransomware advisories in October 2020, and OFAC sanctioned its first virtual currency exchange in September 2021 for facilitating ransomware payments.

In this article, Christopher Sidler, Debra Bonosconi, Valtteri Tamminen, and Dominic Zagara discuss these focus areas and key takeaways for firms with virtual currency exposure based on OFAC’s guidance.