King & Spalding on 19th February published a briefing which says that as Iran, Russia, Venezuela, and other sanctioned jurisdictions warm to cryptocurrency this raises a question: could sanctioned countries use cryptocurrencies to avoid regulatory systems designed to keep them from participating in the global marketplace?  It reminds one that OFAC has explicitly stated that compliance obligations are the same, regardless of whether a transaction is denominated in cryptocurrency or traditional fiat currency, and has also issued specific guidance on compliance obligations.  The article says that it would be wise to align compliance procedures now to avoid running foul of regulators down the line.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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