OFAC Virtual Currency Guidance Brochure

Virtual Currency & U.S. Sanctions Compliance

Source: OFAC

As virtual currencies gain traction in the global financial system, they also introduce new risks—particularly in relation to U.S. economic sanctions. The use of digital assets like cryptocurrency can expose individuals and businesses to violations, especially if transactions involve sanctioned entities or jurisdictions.

To address these emerging challenges, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued specific guidance for the virtual currency industry. This includes participants such as technology companies, wallet providers, exchanges, miners, administrators, and everyday users. Each has a critical role in ensuring digital assets are not used to bypass U.S. sanctions and undermine national security or foreign policy.

Key Compliance Responsibilities

Virtual currency transactions are subject to the same OFAC sanctions as traditional financial transactions. Members of the virtual currency ecosystem must ensure they do not—directly or indirectly—engage in dealings with blocked individuals, entities, or jurisdictions.

OFAC’s guidance helps the industry:

Identify sanctions-related risks in digital asset transactions
Implement effective compliance programs
Strengthen cybersecurity to deter illicit activity

Real-World Examples of OFAC Sanctions Involving Virtual Currency

March 2020: OFAC sanctioned two Chinese nationals for laundering over $100 million in virtual currency stolen from cryptocurrency exchanges on behalf of North Korea. These individuals used complex layering tactics, including buying over $1 million in digital music gift cards.
September 2021: A Russian cryptocurrency exchange was designated for facilitating transactions linked to ransomware operations. Analysis revealed that more than 40% of the platform’s transactions were tied to illicit actors, involving proceeds from multiple ransomware variants.

These cases highlight the increasing sophistication of bad actors and the growing importance of robust sanctions compliance in the virtual currency space.

View the official OFAC Virtual Currency Guidance Brochure here.

Zaher Fallahi, Iran OFAC License Attorney, CPA, advises clients nationwide on Office of Foreign Assets Control (OFAC) Compliance, U.S. Tax Law, Cryptocurrency & Stolen Crypto Tax, Foreign Gifts and Foreign Inheritance.

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Amir Baradaran Rafii

3 months ago

Mr. Fallahi is a great tax attorney who provided excellent service and professional guidance throughout the entire process. He is extremely knowledgeable, always made himself available, answered all of my questions, and communicated clearly every step of the way. I truly appreciated his responsiveness, attention to detail, and the confidence he brought throughout the process. I highly recommend his services.

Response from the owner:Dear Ami, Thank you very much for your thoughtful and kind words. It was truly my pleasure to assist you. I sincerely appreciate the trust and confidence you placed in me throughout the process. I strive to provide responsive communication, careful attention to detail, and practical guidance so clients can make informed decisions during what is often a stressful and complex tax matter. I am grateful that you found our work together helpful. Thank you again for your recommendation and for the opportunity to be of service. I wish you continued success and all the very best moving forward. Respectfully, Zaher Fallahi, Attorney at Law, CPA & Team

susan nezami

1 year ago

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1 year ago

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Response from the owner:Dear Mr. Alagha, Thank you sincerely for your generous recommendation and kind words. I truly appreciate the confidence you placed in me to assist your client with such a complex matter. It was a pleasure collaborating with you—an esteemed tax professional in your own right—and I’m pleased we achieved a successful outcome. Your professionalism and cooperative spirit were key to ensuring a smooth and efficient process. I look forward to the opportunity to work together again in the future. Warm regards, Zaher Fallahi, Attorney at Law, CPA & Team

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1 year ago

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Response from the owner:Dear Harry and the family, Thank you very much for your thoughtful feedback. It was truly a pleasure assisting your family with this important real estate matter. I understand how sensitive these situations can be, especially when they involve our elderly loved ones, and I’m glad I could help bring clarity and resolution. Your valuable cooperation is also appreciated. Please do not hesitate to reach out if I can be of assistance in the future, and I greatly appreciate your recommendation to others. Wishing you and your family all the best. Kind regards, Zaher Fallahi, Esq., CPA

Parveez Oliaii

1 year ago

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Response from the owner:Dear Doctor Oliaii: Thank you sincerely for your kind words and for taking the time to share your experience. Coming from a respected member of the medical community like yourself, your praise means a great deal to me and my team. We are grateful for the opportunity to assist you since 2011 and will always strive to uphold the highest standards of service. Respectfully, Zaher Fallahi, Attorney At Law, CPA, and Team.

BABAK KHATIBLOO

1 year ago

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Response from the owner:Dear Babak: Thank you so much for your kind words and thoughtful review! I'm truly grateful for the opportunity to assist you with your tax and legal matters. It's always my goal to provide clear, comprehensive guidance, and I'm glad to hear that you found the dual perspective as both a lawyer and CPA helpful. Your trust means a lot, and I look forward to continuing to support you whenever you need. Warm regards, Zaher Fallahi, Attorney At Law, CPA and Team

Bijan Sadri

1 year ago

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Response from the owner:Dear Dr. Sadri: Thank you so much for taking the time to share your experience with respect to taxation of individual and corporations, FBARs, foreign gifts and other international tax matters. We're pleased to have provided you with exceptional support over the years, and we appreciate your trust in our team. We're honored to have clients like you who value precision, professionalism, and proactive solutions. We'll continue striving to deliver top-notch services for you years to come. Thanks again for the recommendation! Respectfully, Zaher Fallahi, Attorney At Law, CPA and Team.

Infinity Air

1 year ago

A great lawyer with a great experience. Thank you Zaher!

Response from the owner:Thank you so much for your kind words! It was an honor meeting you yesterday, and I’m really glad I could assist. Please don’t hesitate to reach out if you have any further questions or need support down the line. Wishing you all the best! Warm regards, Zaher

Ali G.

1 year ago

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Response from the owner:Dear Captain Ali: Thank you so much for your thoughtful and generous review. It was truly a pleasure assisting you with your legal and tax matters involving sale of your international property and compliance with the U.S. Treasury’s Office of Foreign Assets Control (OFAC) Regulations and U.S. International Tax Laws. I’m glad to hear that our guidance helped bring you peace of mind throughout what can indeed be a complex process. Your kind words about my approach and professionalism mean a great deal to me. I’m always committed to providing tailored, clear, and practical legal advice, and I’m grateful for the trust you placed in Zaher Fallahi, Attorney At Law, CPA. Wishing you continued success and all the best in your future endeavors and flights, Captain. Warm regards, Zaher Falahi, Attorney At Law, CPA, and Team

Shahid Alam

1 year ago

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Response from the owner:Thank you for your generous words, Mr. Alam. It was truly a privilege to be of service to you. I thoroughly enjoyed working with your esteemed team and felt like an honorary member throughout the process. Your collective determination played a key role in persuading the IRS to resolve the matter in your favor. My warmest regards to you, your team, and the honorable Chairman of the Board. Sincerely, Zaher Fallahi, Tax Attorney, CPA

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1 year ago

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Response from the owner:Thank you so much for your kind words, Georgina. It was truly an honor to serve your remarkable team. Your cooperation, along with George’s unwavering support, played a crucial role in the successful resolution of your IRS case. Wishing continued success to all of you. Warm regards, Zaher Fallahi, Tax Attorney, CPA

Graham Mitchell

1 year ago

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Response from the owner:Wow—has it really been 14 years? It’s truly been an honor to serve you over the years. My associates and I deeply appreciate your continued trust in us, both for tax and legal matters. Thank you for your kind words and for taking the time to share your experience. Warm regards, Zaher Fallahi, Tax Attorney, CPA

OFAC Virtual Currency Guidance Brochure

Virtual Currency & U.S. Sanctions Compliance

Key Compliance Responsibilities

Real-World Examples of OFAC Sanctions Involving Virtual Currency

TestimonialsWhat our clients say about us

Testimonials
What our clients say about us