Are Iranian digital asset exchanges blocked under OFAC sanctions?
OFAC's answer
Yes. [Executive Order (E.O.) 13599](https://ofac.treasury.gov/media/5931/download?inline), as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599 regardless of whether it is listed on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List). Iranian digital asset exchanges meet the regulatory definition of an "Iranian financial institution" as persons that engage in the business of activities described in section [560.324 of the ITSR](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560/subpart-C/section-560.324). All property and interests in property of Iranian digital asset exchanges in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked pursuant to section 560.211 of the ITSR and must be reported to OFAC. See [FAQ 160](https://ofac.treasury.gov/faqs/160) for additional information regarding the sanctions implications of E.O. 13599. For additional information regarding the application of sanctions to digital assets, please see FAQs [559](https://ofac.treasury.gov/faqs/559), [560](https://ofac.treasury.gov/faqs/560), [561](https://ofac.treasury.gov/faqs/561), [562](https://ofac.treasury.gov/faqs/562), [563](https://ofac.treasury.gov/faqs/563), [594](https://ofac.treasury.gov/faqs/594), [646](https://ofac.treasury.gov/faqs/646), and [647](https://ofac.treasury.gov/faqs/647), as well as [OFAC's Sanctions Compliance Guidance for the Virtual Currency Industry](https://ofac.treasury.gov/media/913571/download?inline).
Related programs
Related FAQs
- #160Section 1 of E.O. 13599 blocks all property and interests in property of the Government of Iran, including the Central Bank of Iran, and of all Iranian financial institutions, that are in the United States, that come within the United States, or that come within the possession or control of U.S. persons (including overseas branches). Can you provide further clarification about this provision of E.O. 13599?
- #559For purposes of OFAC sanctions programs, what do the terms "digital currency," "digital currency wallet," "digital currency address," and "virtual currency" mean?
- #560Are my OFAC compliance obligations the same, regardless of whether a transaction is denominated in digital currency or traditional fiat currency?
- #561How will OFAC use its existing authorities to sanction those who use digital currencies for illicit purposes?
- #562How will OFAC identify digital currency-related information on the SDN List?
- #563What is the structure of a digital currency address on OFAC’s SDN List?
- #594Is it possible to query a digital currency address using OFAC’s Sanctions List Search tool?
- #646How do I block digital currency?
- #647Should an institution tell its customer that it blocked access to their digital currency and, if so, how does the institution explain it to the customer?