OFAC FAQ (Current) # 646- Questions on Virtual Currency (PDF contains all versions)

Date issued: Oct. 16 2021

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TURBOFAC Commentary (674 words)

Notes:

1) FAQ initially issued in 2018, connection with designation of certain Iranians pursuant to the Cyber-related Sanctions Regulations and EO 13694 [1]. Amended on October 15, 2021, concurrent with the release of Sanctions Compliance Guidance for the Virtual Currency Industry (2021 Brochure).

[1] See press release at: https://home.treasury.gov/news/press-releases/sm556

The amended version changes references from "digital currency" to "virtual currency," with OFAC defining "Virtual currency" to mean "a digital representation of value that functions as (i) a medium of exchange; (ii) a unit of account; and/or (iii) a store of value; and is neither issued nor guaranteed by any jurisdiction." (See FAQ # 559).

Another significant difference between the original and amended FAQs is that the original FAQ referenced “digital currency wallet[s] associated with...