The recent 2019 Congressional hearings and regulatory scrutiny on cryptocurrency highlighted the provocative nature of the innovation. And, while federal authorities from the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) continue to test competing theories over whether this technological medium is a security or a medium, other agencies are pressing ahead with traditional applications of longstanding law.

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has been active in exerting control over these digital assets and has taken some noteworthy action. OFAC administers approximately 30 unique economic and trade sanctions programs in order to keep funds and resources away from terrorists, drug traffickers, oppressive government regimes and other entities that are involved in activities that the U.S. views as a threat.