{"QuestionID":92721,"AnswerID":38459,"AnswerName":"Anonymous Attorney"}
Posted on / Nov. 28, 2018 00:00:00
Once it has been determined that your institution is holding digital currency that is required to be blocked pursuant to OFAC s regulations, you must ensure that access to that digital currency is denied to the blocked person and that your institution complies with OFAC regulations related to blocked assets. Institutions may choose, for example, to block each digital currency wallet associated with the digital currency addresses that OFAC has identified as being associated with blocked persons, or opt to use its own wallet to consolidate wallets that contain the blocked digital currency (similar to an omnibus account) titled, for example, Blocked SDN Digital Currency. Each of these methods is satisfactory, so long as there is an audit trail that will allow the digital currency to be unblocked only when the legal prohibition requiring the blocking of the digital currency ceases to apply. The institution is not obligated to convert the blocked digital currency into [traditional] fiat currency (e.g., U.S. dollars). Blocked digital currency must be reported to OFAC within 10 business days. Questions about whether a transaction should be blocked should be directed to OFAC at 202-622-2490 or mailto: ofac_feedback@treasury.gov. [11-28-2018]
