Sanctions Compliance Guidance for the Virtual Currency Industry

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (1334 words)

Notes:

1) BACKGROUND

This document is the first item to be filed to OFACs’ “OFAC Information for Industry Groups” page since 2017. Such “industry group” brochures are ordinarily meant to serve the function of making industry actors aware of the most important aspects of OFAC’s already-public guidance, without adding much in the way of novel statements that bear on the scope and operation of OFAC’s sanctions provisions. The brochures do, however, serve to signal OFAC’s due diligence expectations as they relate to transaction types common for a given industry, and that sense may be referred to in determinations of whether a given person knew or had a “reason to know” about the facts and circumstances underlying a potential violation. see generally General Note on the Terms "Knowingly," "Should Have Known" And "Reason to Know" In the Primary Sanctions,...

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Sanctions Compliance Guidance for the Virtual Currency Industry

TURBOFAC Commentary (1334 words)