Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

The U.S. Treasury's Office of Foreign Assets Control (OFAC) entered into a $3,103,360 settlement with Exodus Movement, Inc., a U.S.-incorporated non-custodial / self-custody crypto wallet software company, to resolve 254 apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) committed between October 17, 2017 and January 4, 2019. Exodus customer-support staff provided technical and account-related support — and in 12 of the 254 instances recommended the use of virtual private networks (VPNs) to circumvent partner-exchange geoblocking controls — to users who self-identified as located in Iran, in violation of the ITSR's prohibition on the export of services to Iran (§ 560.204) and, for the 12 egregious cases, the facilitation prohibition (§ 560.203). OFAC deemed the 12 VPN-coaching cases "egregious" because Exodus personnel were generally aware of U.S. sanctions and the company's own terms of use prohibited Iran usage, yet support staff actively helped Iranian users evade controls. Exodus separately committed to invest $630,000 in additional sanctions compliance controls. The settlement is structurally novel as the first OFAC enforcement action against a Web3-infrastructure / non-custodial wallet-software vendor and establishes that OFAC will assert jurisdiction over self-custody software providers based on customer-support facilitation conduct, not just custodial flow control.

On 8 September 2025, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated 19 targets — companies and individuals based in Burma (Myanmar) and Cambodia — for operating or supporting networks of scam compounds that defraud Americans through virtual-currency investment fraud ("pig butchering") schemes. Nine targets operate out of Shwe Kokko, Burma, a scam-compound hub under the protection of the OFAC-designated Karen National Army (KNA), and ten targets are based in Cambodia, including Heng He Bavet's casino-linked complex in Bavet. Designations were made pursuant to Executive Order 13581 (transnational criminal organizations) and, for the Burma-based Shwe Myint Thaung Yinn Industry & Manufacturing Company, also under Executive Order 14014 (Burma sanctions program) as an entity acting on behalf of designated individual Tin Win. Treasury cited a U.S. government estimate that Americans lost over $10 billion in 2024 to Southeast Asia-based scam operations, a 66% increase over the prior year. All U.S.-nexus property of designated persons is blocked and U.S. persons are prohibited from transacting with them.

The Office of Foreign Assets Control (OFAC) issued a final rule on 21 March 2025 adopting without change its 13 September 2024 interim final rule that doubled the recordkeeping retention requirement for transactions subject to OFAC regulations from five years to ten years. The extension aligns 31 CFR 501.601, paragraph IV.B of appendix A to part 501, and 31 CFR 515.572 with the 10-year statute of limitations for IEEPA and TWEA violations enacted by the 21st Century Peace through Strength Act of 24 April 2024. The interim final rule's 10-year retention obligation became effective 12 March 2025; the final rule confirmed the IFR text without modification.

The Office of Foreign Assets Control (OFAC) issued a final rule on 8 October 2024 amending the Reporting, Procedures and Penalties Regulations (RPPR) at 31 CFR Part 501. The rule finalises portions of OFAC's 10 May 2024 interim final rule and adds three exceptions to the requirement to file a report with OFAC concerning blocked property that is unblocked or transferred. It also implements other technical clarifications to OFAC's reporting framework. The rule takes effect on 7 November 2024.

FinCEN issued a final order, published in the Federal Register on 11 October 2024 (signed 26 September 2024), prohibiting US covered financial institutions from engaging in transmittals of funds to or from PM2BTC, a virtual-currency exchange operating outside the United States and identified as a primary money-laundering concern in connection with Russian illicit finance. The order is the first use of FinCEN's special- measure authority under Section 9714(a) of the Combating Russian Money Laundering Act, as amended by the FY 2022 NDAA (codified at 31 U.S.C. 5323). The action was coordinated with same-day OFAC SDN designations of related entities (Cryptex) and individuals (Sergey Sergeevich Ivanov of Taleon Holdings).

The Office of Foreign Assets Control (OFAC) issued an interim final rule (IFR) on 10 May 2024 (FR Doc 2024-10033, 89 FR) amending the Reporting, Procedures and Penalties Regulations (RPPR) at 31 CFR Part 501. The IFR overhauls OFAC's reporting framework by requiring electronic submission of certain reports through the OFAC Reporting System (ORS), expanding the rejected-transaction reporting obligation to all U.S. persons (not only U.S. financial institutions), modifying blocked-property reporting procedures, updating procedures for petitions for administrative reconsideration and property-blocked-in-error requests, and revising FOIA-availability provisions. The IFR took effect on 8 August 2024 and was subsequently finalised — with three new exceptions to the blocked-property reporting requirement — by the 8 October 2024 final rule (FR Doc 2024-23217, effective 7 November 2024).

The U.S. Treasury's Office of Foreign Assets Control (OFAC) reached a $968,618,825 settlement with Binance Holdings, Ltd. — a Cayman Islands–domiciled virtual-currency exchange — to resolve civil liability for 1,667,153 apparent violations of multiple sanctions programs (Iran, Cuba, North Korea, Syria, and the Crimea region of Ukraine) committed between August 2017 and October 2022. OFAC determined the apparent violations were not voluntarily self-disclosed and that Binance's conduct was egregious; the settlement requires a five-year independent compliance monitor and was announced concurrently with parallel DOJ, FinCEN, and CFTC resolutions totaling approximately $4.3 billion in aggregate (including criminal forfeiture and BSA/AML penalties), alongside a separate criminal plea by founder Changpeng Zhao. The settlement is the largest civil monetary penalty in OFAC's history.

FinCEN issued an order on 18 January 2023, published in the Federal Register on 23 January 2023 (FR Doc 2023-01189), prohibiting US covered financial institutions from transmitting funds to, from, or through Bitzlato Limited, a virtual-currency exchange incorporated in Hong Kong and identified as a primary money-laundering concern in connection with Russian illicit finance. The order invokes Section 9714(a) of the Combating Russian Money Laundering Act, as amended by Section 6106 of the National Defense Authorization Act for Fiscal Year 2022 (31 U.S.C. 5323). The action was coordinated with a DOJ criminal arrest of Bitzlato co-founder Anatoly Legkodymov and a parallel Europol/Eurojust-supported disruption of Bitzlato's infrastructure, effective 18 January 2023.