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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.

publication, OFAC’s SDN List contains over 9,000 names (or variations thereof) of designated individuals and entities located around the world, as well as identifications of certain property blocked by sanctions such as vessels and aircraft. The SDN List is frequently updated, and you

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