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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.
2. OFAC. U.S. Department of the Treasury Sanctions Compliance Guidance for the Virtual Currency Industry. The Office of Foreign Assets Control (OFAC) is the office within the U.S. Department of the Treasury that is responsible for administering
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