Body of Law:
OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry is the most detailed industry-specific guidance issued by the agency in many years. Although only briefly noted in the guidance, its publication appears to have been motivated in part by the nexus between virtual currency and the increasing threat of ransomware attacks. As explained in a Treasury press release, the guidance is part of a whole-of-government effort to combat this threat, which also includes a FinCEN report on pattern and trend information related to ransomware payments. As covered here and here, the virtual currency industry has already been targeted by numerous OFAC enforcement actions. Following the publication of OFAC’s guidance, the agency is likely to take an even harder line against industry participants who fail to implement an effective sanctions compliance program. Whether OFAC will issue similar detailed guidance for other industries remains to be seen.
