On October 15, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published sanctions compliance guidance for the virtual currency industry (the “Guidance”), given that “the growing prevalence of virtual currency … brings greater exposure to sanctions risk.” This Guidance follows (1) the recent and first-ever designation of a virtual currency exchange (SUEX OTC, S.R.O) by the OFAC (see our recent post on this here), and (2) the launch of the National Cryptocurrency Enforcement…