OFAC FAQ (Current) # 647- Questions on Virtual Currency

Date issued: Nov. 28 2018

TURBOFAC Commentary (129 words)

Notes:

1) Digital currency analogue of FAQ 41, saying the same thing about blocked funds generally with respect to banks. Given the lack of a General License associated with this FAQ and presuming that this is permissible even if the customer itself is a blocked party, OFAC impliedly determines that a customer advising a blocked party does not constitute a "service" provided to the customer, or if the customer is not blocked, a service "with respect to" the blocked property. This suggests limitations to OFAC's expansive interpretation of what constitutes an impermissible discussion with an SDN (compare e.g. FAQ 547).

2) See OFAC Director A. Gacki; Interview Concerning Cryptocurrency Industry Compliance (Transcript), for a collection of notable statements concerning OFAC compliance expectations vis-a-vis the cryptoasset industry.