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Virtual currency in sanctioned jurisdictions: stepping outside of SWIFT

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 10 June 2019

Issue publication date: 23 July 2019




To understand and analyze sanctions evasion and enforcement via virtual currencies.


Discusses various jurisdictions’ attempts to further the use of virtual currency to facilitate and maximize access to international funds; analyzes the aspects that make virtual currency uniquely suited to evade sanctions; suggests best practices for industry participants to be sure to account for the differences in crypto asset structure and related risks.


The US Treasury Department’s Office of Foreign Assets Control (OFAC) has explicitly stated that despite virtual currency’s anonymity, industry participants are still responsible for policing and enforcing client compliance. Although sanctioned jurisdictions are thinking creatively about ways around SWIFT, the use of virtual currency to skirt sanctions presents certain challenges.

Practical implications

Virtual currency industry participants should understand OFAC’s specific guidance regarding compliance obligations in the cryptocurrency space, and should implement best practices and conservative measures to avoid unknowingly running afoul of sanctions laws.


Expert analysis and guidance from experienced investigations and sanctions lawyers.



Kirkpatrick, K., Savage, C., Johnston, R. and Hanson, M. (2019), "Virtual currency in sanctioned jurisdictions: stepping outside of SWIFT", Journal of Investment Compliance, Vol. 20 No. 2, pp. 39-44.



Emerald Publishing Limited

Copyright © 2019, King & Spalding LLP.

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