OFAC FAQ (Current) # 1079 - Cyber-related Sanctions (PDF contans all versions)

Date issued: Nov. 08 2022

Last substantive commentary amendment:
Aug. 19 2023

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TURBOFAC Commentary (107 words)

Notes:

1) This FAQ contains a notable implicit "extinction of interest" determination, i.e. that Tornado Cash does not have an "interest" in virtual currency that passed through it prior to the designation (but contrast FAQ # 1078).

2) FAQ amended on 11-8-22 to change "U.S. persons should be prepared to provide, at a minimum" to "Applicants should be prepared to provide, at a minimum". This is probably due to U.S. persons cryptocurrency exchanges holding property on behalf of non-U.S. persons, where in many cases the non-U.S. person accountholder would be the one applying to OFAC for an unblocking license.