The Office of Foreign Assets Control (OFAC), a division of the U.S. Treasury Department has published 5 Frequently Asked Questions addressing compliance obligations for virutal currency transactions.

These FAQs define commonly used terms associated with virtual currency such as “digital wallet”, “digital currency address”, and “digital currency” among others.  These FAQs also address compliance obligations for digital transactions as well as sanctions for those who use digital currency for illicit transactions.

OFAC may soon add digital currency addresses that are associated with blocked persons to its list of Specially Designated Nationals and Blocked Persons (SDN List).  Firms will be expected to consult the SDN list to identify wallets or digital currency identifiers that they believe are owned or associated with a blocked person.

To ensure your AML program addresses these digital currency regulatory obligations, please visit the OFAC FAQs here.

As a reminder, AML audits must be performed on an annual basis within a 12 month period.  If your AML program is due to be reviewed, please contact Mike@cogcpa.com or call 630-351-8942.