Clifford Chance law firm paper of 6th November says trade finance is one of the areas likely to benefit from blockchain technology first by becoming cheaper, faster and more accessible. However, it also says developers and market participants should be mindful to consider the sanctions implications given the extraordinary reach of sanctions and the magnitude of the penalties for breach. Any US-owned blockchain technology would remain subject to OFAC regulation, and may be subject to export controls. Similarly, if the technology is owned or licensed by a US person and supplied to, or used by, someone or somewhere subject to sanctions this could be prohibited. There could be similar problems under EU or other sanctions regimes. The paper summarises what developers need to bear in mind from a sanctions perspective.
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