On Wednesday, November 28, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control took the significant step of adding digital currency addresses to its list of identifiers for certain designated individuals. The decision was announced as part of the Treasury’s joint action with the U.S. Department of Justice, in which charges were filed against an alleged Iranian hacking enterprise involved in a ransomware scheme. The Treasury identified the two alphanumerical wallet addresses utilized by the malicious actors and included them on the list of identifiers for designated individuals. By listing them, any person or business that engages in transactions with these two addresses “could be subject to secondary sanctions.” The decision by the Treasury to include digital currency wallet addresses on the SDN list should immediately alert those entities that transact in digital assets and incentivize them to take appropriate action. Primarily, entities should ensure these addresses are included in their monitoring tools and that any transactions initiated with or through these accounts are blocked.
In-depth analysis by Murphy & McGonigle attorney Maxwell T.S. Thompson can be found on Law360.
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Blockchain technology utilizes a distributed digital ledger to record and track information, and can be leveraged to gain transparency and certainty in transactions ranging from cryptocurrency to supply chain tracking. This blog provides information on the legal developments surrounding implementation of blockchain technology, with an initial focus on the financial services sector.