OFAC FAQ (Current) # 559 - Questions on Virtual Currency (PDF contains all versions)

Date issued: Oct. 16 2021

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TURBOFAC Commentary (183 words)

Notes:

1) This FAQ was initially issued in 2018, and was amended on October 15, 2021, concurrent with the release of Sanctions Compliance Guidance for the Virtual Currency Industry (2021 Brochure).

The original FAQ defined "virtual currency" as the amended version does, but the amended version also included "does not have legal tender status in any jurisdiction" in the definition. The change is presumably a reaction to El Salvador having made Bitcoin "legal tender" in that country. (See e.g. https://www.npr.org/2021/09/07/1034838909/bitcoin-el-salvador-legal-tender-official-currency-cryptocurrency).

2) See e.g., FAQ 551 (removed), where OFAC states that it would consider a certain virtual currency issued by the Venezuelan Government to be "new debt" of that Government. Similarly, one could expect any virtual current of which the creation or management is connected to an embargoed country to dealing in goods or...