In the complaint the DOJ alleges that a US citizen, using an IP address in the US, operated an online payments and remittances platform ("Payments Platform") based in a Sanctioned County. The Payments Platform advertised its services as designed to evade US sanctions, including through purportedly untraceable virtual currency transactions. OFAC, Sanctions Compliance Guidance for Virtual Currency (“OFAC Guidance”), at 1 (Oct. 2021) (emphasis added), 5 ; see also U.S. Dep’t of the Treasury, Questions on Virtual Currency (Mar. Issue Two: sanctions do not apply to virtual currency? The Department of Justice can and will criminally prosecute individuals and entities for failure to comply with OFAC’s regulations, including as to virtual currency."

Source: Washington Post May 17, 2022 18:48 UTC