Beau Barnes and Jake Chervinsky of Kobre & Kim LLP are litigators and government enforcement defense attorneys who specialize in disputes and investigations related to digital assets. This article is not intended to provide legal advice.

For the past year, the cryptocurrency industry’s attention has focused on the Securities and Exchange Commission’s deliberations over how to enforce U.S. securities laws. But the past two months have seen important developments on a new regulatory front: the application of U.S. sanctions laws by the Treasury Department’s Office of Foreign Assets Control (OFAC).

Last week, OFAC sanctioned two Iranian individuals for cyberattacks against U.S. networks. For the first time ever, OFAC targeted both the individuals who committed the offense and their associated bitcoin addresses.

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