A non-U.S. customer wants to use crypto to pay us from a Russia-linked wallet. Do sanctions rules still apply even though the payment is not in dollars?
We are a U.S.-touching crypto business and a customer is trying to settle in virtual currency from a wallet that raises Russia-related sanctions concerns. One manager suggested that because no U.S. dollar wire is involved, the OFAC analysis might be lighter. That sounds dangerous to me, but I want an official answer before escalating it.
If OFAC really treats virtual currency transactions the same way as fiat for sanctions purposes, then the wallet source and counterparty analysis should be treated as fully live sanctions questions and not as optional enhancements.
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