With governments around the globe cracking down on all aspects of the cryptocurrency market, it seems like new regulatory risks arise every day. Add U.S. sanctions to that list.

On Jan. 19, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the primary sanctions enforcer in the U.S., announced that any U.S. person dealing in Venezuela’s soon-to-be-introduced cryptocurrency, the petro, could run afoul of U.S. sanctions against the Venezuelan government.

Couple that with recent comments from U.S. Secretary of the Treasury, Steven Mnuchin, warning that the U.S. is determined not to let bitcoin wallets become a new version of the Swiss bank account, and it appears that the Treasury Department is poised to wade into cryptocurrency regulation in a major way.

Although the potential sanctions risks associated with cryptocurrencies are similar in some respects to money laundering and terrorist financing risks that have garnered attention recently, they present some unique challenges.

OFAC maintains a blacklist of persons and entities that are essentially prohibited from dealing with U.S. persons, U.S. goods and services or the U.S. financial system. Direct violations of U.S. sanctions, or assisting others in efforts to evade U.S. sanctions, can result in significant financial or, in egregious cases, criminal penalties. Companies inside and outside of the U.S. have ample incentives to guard against such violations, but the anonymity afforded by cryptocurrency transactions makes compliance with such restrictions difficult.

If OFAC turns its eye toward cryptocurrencies, however, it could be only a matter of time before it makes an example out of one or more entities in an effort to send a message to the market and create a deterrent effect.

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