On 20 October, an article from Doughty Street Chambers starts by asserting that the increased use of virtual currency as a payment method brings greater exposure to sanctions risks, whether in respect of UN and trade sanctions or listed individuals and entities. Taking as a starting point recent OFAC advice, it says that although directed to liability in the US, the considerations involved will also inform good compliance practices under the UK autonomous sanctions regime.  It says that the advice from OFAC highlights sanctions compliance best practices tailored for the crypto-asset sector applying the 5 essential components of OFAC’s preferred sanctions compliance programme.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

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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