We blocked sanctioned crypto on our platform. Do we have to liquidate it into dollars or put it in an interest-bearing account?
Our compliance team blocked virtual currency connected to a sanctioned person, but treasury is now asking how the blocked property must actually be held. One internal view is that we should immediately convert everything to U.S. dollars and move it into an interest-bearing account because that is how people think about traditional blocked funds. Another view is that virtual currency has its own handling rule.
I need the answer from OFAC's own guidance. If OFAC allows blocked virtual currency to remain as virtual currency and does not require an interest-bearing account, that changes the incident runbook and the controls we build around the wallet structure.
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