OFAC Sanctions Tracker: How Sanctions Impact Crypto Crime

NFTs are a new and innovative part of the crypto ecosystem that have the potential to change and update many business models for the Web 3 world. A smart contract enables multiple scripts to engage with each other using clearly defined rules, to execute on tasks which can become a coded form of a contract. They have revolutionized the digital asset space because they have enabled decentralized exchanges, decentralized finance, ICOs, IDOs and much more. A huge proportion of the value created and stored in cryptocurrency is enabled by smart contracts. The world of crypto now contains many coins and tokens that we feel unable to verify.

The publication consolidates guidance that OFAC previously provided in answers to FAQs, enforcement actions, and other statements. Most of the guide is dedicated to the general regulatory framework for sanctions, which applies to all US financial institutions. Accordingly, in this alert, we outline the framework and provide more detail regarding the material specific to virtual currency. In discussing the importance of conducting risk assessments, the guidance mentions a settlement agreement that OFAC entered into earlier this year with a US virtual currency payment service provider.

The global crypto market cap is $3.26T, a 5.22% decrease over the last day. If you enjoyed this post, check out Ranking the Largest Bitcoin ETFs in the U.S. In this graphic, we rank the top eight Bitcoin ETFs in the U.S. by their total assets under management. This graphic, via Visual Capitalist’s Marcus Lu, ranks the 15 most valuable Bitcoin addresses globally as of May 2024, based on BitInfoCharts’ Bitcoin Rich List.

The first sentence of Treasury’s press release describes the 2021 Ransomware Advisory and SUEX designation as a “whole-of-government” effort to counter ransomware, which was reflected clearly throughout the US government’s documents. This level of cooperation reflects the seriousness with which the US government views the threat of ransomware to both private and governmental entities.SUEX has been described as a “nested exchange,” which carries additional risk for parties that interact with these types of digital asset platforms. Similar to the concept of “nested accounts” in traditional banking, nested exchanges maintain accounts on major virtual currency exchanges, which provide them with greater access to liquidity while still allowing them to facilitate business for their customers (many of whom could be cybercriminals). Instead of playing whack-a-mole by publishing digital currency addresses as identifiers, most of which are obsolete the moment they hit the SDN List, OFAC has now targeted a company that provides direct financial assistance to perpetrators of ransomware attacks. Companies, banks, and individuals involved in the digital currency marketplace need to ensure that they are not involved in transactions with SUEX, either directly or indirectly. Engaging in transactions with SUEX or other sanctioned parties could expose otherwise lawful actors in the digital currency space to sanctions or enforcement actions by the US government.

On September 21, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) took two important actions to counter the growing threat of ransomware attacks and the malicious cyber actors who support them, often through the use of digital assets. First, it designated SUEX OTC, S.R.O. (SUEX), as a Specially Designated National (SDN), which marks the first time that OFAC has added a virtual currency exchange to the SDN List. Second, it issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments” (2021 Ransomware Advisory), which provides additional guidance to companies on how to mitigate these sanctions risks proactively.

We calculate the total cryptocurrency market capitalization as the sum of all cryptocurrencies listed on the site. We receive updated cryptocurrency prices directly from many exchanges based on their pairs. Department of the Treasury has issued economic sanctions to achieve foreign policy and national security objectives. Today, the Treasury’s Office of Foreign Assets Control (OFAC) sanctions countries, individuals, companies, and groups — like international drug traffickers or terrorists — that pose specific threats to U.S. interests.

It notes that while the company conducted sanctions screenings of its direct customers—merchants located in the United States and elsewhere—it failed to screen available information about the individuals who used its payment processing platform to buy products from those merchants. They can be used as art, a way to share QR codes, ticketing and many more things. The first breakout use was for art, with projects like CryptoPunks and Bored Ape Yacht Club gaining large followings. We also list all of the top NFT collections available, including the related NFT coins and tokens.. We collect latest sale and transaction data, plus upcoming NFT collection launches onchain.