OFAC on Bitcoin—Learning Before Actively Regulating

Before a government agency issues regulations implementing a new law—or applies existing regulations to a new technology—it has to do some groundwork.  The agency will interpret its authorizing legislation and executive orders before gathering evidence to support the exercise of its rulemaking and enforcement authorities.  Some agencies are subject to…

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OFAC Announces Settlement with PayPal for Apparent Sanctions Violations

On March 25, 2015, the Department of the Treasury’s Office of Foreign Assets Controls (OFAC) announced a settlement with electronic funds transfer giant PayPal, Inc. At issue were almost 500 transactions totaling approximately $44,000 in violation of various U.S. sanctions programs, including for Iran, Cuba, Sudan, proliferation of weapons of…

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Bitcoin and OFAC

While some regulators are struggling to fit bitcoin’s innovative peg into preexisting holes—is bitcoin a currency or a commodity or something else entirely?—the novelty of digital currencies falls squarely within the regulatory purview of some agencies. One example is the Office of Foreign Assets Control, or OFAC, the unit within…

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