Client Alert: 4 Key Questions Answered in OFAC’s Guidance for the Virtual Currency Industry

On October 15, 2021, the US Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) issued guidance to help the virtual currency industry navigate and comply with OFAC sanctions. The guidance improves on earlier FAQs by providing sanctions compliance best practices tailored for the virtual currency industry and reflects Treasury’s commitment to “modernize and strengthen” US sanctions programs to adapt to what Treasury’s October 18, 2021 report on the 2021 Sanctions Review described as “a changing world where financial innovation, shifts in global economic activity, and new geopolitical challenges are redefining how economic power can be used to support national security objectives.” The straightforward, visual format of this guidance also exemplifies Treasury’s renewed effort, as noted in the 2021 Sanctions Review report, to “enhance its public messaging” on sanctions and “improve public understanding of the intent and effect of sanctions.” 

Read the full alert here.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

Client Alert: 4 Key Questions Answered in OFAC’s Guidance for the Virtual Currency Industry

On October 15, 2021, the US Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) issued guidance to help the virtual currency industry navigate and comply with OFAC sanctions. The guidance improves on earlier FAQs by providing sanctions compliance best practices tailored for the virtual currency industry and reflects Treasury’s commitment to “modernize and strengthen” US sanctions programs to adapt to what Treasury’s October 18, 2021 report on the 2021 Sanctions Review described as “a changing world where financial innovation, shifts in global economic activity, and new geopolitical challenges are redefining how economic power can be used to support national security objectives.” The straightforward, visual format of this guidance also exemplifies Treasury’s renewed effort, as noted in the 2021 Sanctions Review report, to “enhance its public messaging” on sanctions and “improve public understanding of the intent and effect of sanctions.” 

Read the full alert here.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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