In a FAQ tied to the Russian Harmful Activities Sanctions, the Treasury Department notes:
“U.S. persons, including virtual currency exchanges, virtual wallet hosts, and other service providers, such as those that provide nested services for foreign exchanges, are generally prohibited from engaging in or facilitating prohibited transactions, including virtual currency transactions in which blocked persons have an interest.”
The guidance also bars U.S. persons from engaging in or facilitating prohibited transactions by a non-U.S. person, “including virtual currency transactions involving the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.”
U.S. financial institutions cannot process transactions, including virtual currency transactions, involving targeted financial institutions.
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