Steptoe and Johnson LLP issued the following announcement on Feb. 25.
Blockworks quoted Evan Abrams in a February 25, 2022 article titled "Russian Financiers Could Turn To Crypto To Sidestep US, European Sanctions." The US and Europe levied sweeping economic sanctions against Russia for its invasion of Ukraine. This article examines Russia's pivot towards cryptocurrencies as a means to skirt the sanctions that bar their participation in the global economy.
According to Abrams, the United States Office of Foreign Assets Control (OFAC) "takes the view that its sanctions apply to activity conducted in cryptocurrency. They generally would view a transaction conducted in bitcoin or another asset the same as they would view a transaction conducted in dollars."
Penalties for violating OFAC sanctions may result in up to $20 million in fines and 30 years in prison. Abrams' commentary is summarized by Blockworks, with his explanation that the severity of punishment "depends on whether the violations are against primary or secondary US sanctions. The former requires a US citizen or resident in the mix. When it comes to secondary sanctions, where non-US citizens operate in other countries, OFAC has little legal standing to pursue civil or criminal penalties." Abrams continues that "…what they can do is to essentially impose sanctions on those actors. If one person is interacting with the sanctioned individual, the first person can be sanctioned in a similar manner to the person that they’re interacting with."
Original source can be found here.
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