Written by:Eli Han,Aaron Wolfson , Michael Amberg, Benjamin Li (New York Office)




On October 15, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published its “Sanctions Compliance Guidance for the Virtual Currency Industry” (Guidance). The publication uses a concise and reader-friendly format to inform members of the cryptocurrency industry and the broader public about how OFAC intends to regulate transactions involving cryptocurrencies within the existing framework of sanctions compliance. Most importantly, it outlines the degree of due diligence required to avoid facilitating cryptocurrency transactions with sanctioned individuals and entities and advises cryptocurrency users on best practices as well as the steps they should take if they find themselves transacting with sanctioned individuals and entities.