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Fair Warnings From Ofac’S Settlements With Cryptocurrency Service Providers: Compliance Should Include Lifetime-Of-The-Relationship, In-Process Geolocational Checks, Sarah Jane Hughes
Fair Warnings From Ofac’S Settlements With Cryptocurrency Service Providers: Compliance Should Include Lifetime-Of-The-Relationship, In-Process Geolocational Checks, Sarah Jane Hughes
Articles by Maurer Faculty
In 2022, the Office of Foreign Assets Control (OFAC) announced numerous settlements with cryptocurrency exchanges. These settlements serve as “fair warnings” to all cryptocurrency service providers who are “U.S. persons” or who offer services to U.S. persons. The term “U.S. persons” is defined in 31 C.F.R. §560.314 as “any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.”
This article focuses on these “fair warnings” as they have accumulated from prior settlements and from OFAC’s published guidance …