OFAC Virtual Currency Guidance

OFAC's virtual currency guidance is a series of published advisories and enforcement actions that clarify sanctions compliance obligations for the cryptocurrency industry. Key documents include the 2022 Virtual Currency Advisory and the 2023 DeFi Illicit Finance Risk Assessment.

Key takeaways from OFAC's guidance

• Same rules apply: Sanctions compliance obligations are the same for crypto as for traditional finance.
• Technology-neutral: The legal obligations do not change because the transaction uses a blockchain.
• Industry-wide responsibility: Exchanges, wallet providers, DeFi protocols, mixers, and individual users all have compliance obligations.