OFAC Director A. Gacki; Interview Concerning Cryptocurrency Industry Compliance (Excerpts)

Date issued: Oct. 27 2020

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TURBOFAC Commentary (1143 words)

Notes:

1) BACKGROUND

This is a transcription of an-on-the-record interview of OFAC Director Andrea Gacki, conducted by David Carlisle, Head of Crypto Policy and Regulatory Affairs at Elliptic. A video recording of the interview is freely available at https://www.elliptic.co/webinars-events/financial-regulator-crypto-coffee-webinar-series-with-ofac.

In the interview, Director Gacki, speaking in her capacity as OFAC Director, makes several notable statements concerning the relationship between cryptocurrencies, cryptocurrency-related services and OFAC-administered sanctions laws. Much of the substance of the interview consists of commentary on topics that, as of the date on which the interview was conducted, had not been the subject of any on-the-record statements attributable to OFAC. Note that the interview was conducted two months prior to OFAC’s first ever cryptocurrency-related enforcement action (Civil Enforcement Information - BitGo, Inc.)

2) THE “KNOW OR REASON...