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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.

, unless exempt or authorized by OFAC, U.S. persons are prohibited from engaging in transactions with SDNs or blocked persons, directly or indirectly, and must block any property in their possession or control in which an SDN or a blocked person has an interest. *To learn more about other sanctions lists maintained by OFAC, visit OFAC’s “

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