Industrial Policy & Trade Monitor· 2665 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.