Crypto Never Sleeps: Vigilance Required in OFAC Sanctions Compliance Involving Virtual Currencies and Digital Assets

December 17, 2018

For years, regulators around the world have struggled with whether and how to police the offering and exchange of digital assets (including virtual  currencies such as Bitcoin). In the United States, such efforts were stymied in part by laws and regulations that did not contemplate the rise of distributed and decentralized payment networks. Efforts at regulation were also hampered, however, by a more fundamental problem – digital assets are not “one” single thing but several, and not all digital assets share the same attributes.

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