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1257. Are non-U.S. persons exposed to sanctions for dealing with digital asset exchanges designated pursuant to Executive Order 13902, "Imposing Sanctions with Respect to Additional Sectors of Iran" (E.O. 13902)?
Yes. OFAC's designation of Nobitex, Wallex, Bitpin, Ramzinex, Aban Tether, or any digital asset exchange pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who transact with these exchanges may also face sanctions under E.O. 13902 or other Iran-related authorities. For example, pursuant to E.O. 13902, OFAC has authority to:
1. Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any digital asset exchange designated pursuant to E.O. 13902; or
2, Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign...
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1) See related designation notice at https://home.treasury.gov/news/press-releases/sb0519. The purpose of the FAQ appears to be signaling that there is some intent to impose secondary sanctions on non-U.S. persons for dealings involving the various digital asset exchanges sanctioned (including pursuant to the standard “material support” provision. Note that OFAC regards these entities as “Iranian financial institutions.” Accordingly, transactions involving these entities, which were blocked pursuant to the ITSR (560.211) and EO 13902, can qualify for Iran GL L (covering “transactions and activities that are authorized, exempt, or otherwise not prohibited under the [ITSR] involving Iranian financial institutions blocked pursuant to Executive Order (E.O.) 13902…including transactions and activities authorized by a general or specific license issued pursuant to the ITSR”). Consistent with