OFAC Targets Digital Currency Addresses For the First Time

 
November 30, 2018

In a long-anticipated move, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), on November 28, 2018, took direct aim at the illicit use of digital currencies by identifying two digital currency addresses as associated with two Iranian individuals added to the Specially Designated Nationals and Blocked Persons (“SDN”) List on the same day. As a result, digital currency transactions involving those addresses must be blocked by U.S. persons because they involve the interest of an SDN. Additionally, non-U.S. persons could be subject to so-called “secondary sanctions” for engaging in transactions involving the identified addresses.

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