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CONTENTSI ntroduction ..1 What Is OFAC? ..2 What Are OFAC Sanctions? ..3 The SDN List ..4 How Do You Block Virtual Currency? ..5 Case Study: OFAC Sanctions Involving Virtual Currency ..5 Who Must Comply with OFAC Sanctions? ..6 Strict Liability Regulations ..6 OFAC Requirements and Procedures ..7 Reporting Requirements ..7 Recordkeeping Requirements ..8 License Procedures ..8 Consequences of Noncompliance ..9 Enforcement Enforcement Guidelines ..9 Enforcement Actions ..9 Voluntary Self-Disclosure ..9 Sanctions Compliance Best Practices for the Virtual Currency Industry ..10 Management Commitment ..11 Risk Assessment ..12 Case Study: Diagnosing Risky Relationships ..12 Internal Case Study: Double-Duty Data ..13 Sanctions Screening.

This guidance will assist those in the virtual currency industry in: Evaluating sanctions-related risks in their lines of business. Building a risk-based sanctions compliance program Protecting their business from sanctions violations and intentional misuse of …

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