U.S. actions to Russia-Ukraine war: Sanctions, prohibitions, virtual currency exchanges

The U.S. Treasury and the Administration continue to expand sanctions against Russian entities and individuals as well as to reinforce efforts to disrupt potential sanctions evasion. OFAC’s recent actions specifically focus on the “abuse” of virtual currency by “illicit actors,” including as a payment mechanism for ransomware, and virtual currency exchanges that “disregard anti-money laundering and countering the financing of terrorism (AML/CFT) obligations and allow their systems to be abused by illicit actors.” Companies should watch for the release of Treasury’s National Strategy to Combat Illicit Finance and, in the near term, review and enhance their compliance programs for consistency with OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry as well as the FATF’s recent updated guidance on virtual assets (see KPMG Regulatory Alert).