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In response to Russia invasion of Ukraine, the United States and dozens of its allies and partners around the globe have imposed what the White House has called, "the most impactful, coordinated, and wide-ranging economic restrictions in history." This article (1) provides an overview of OFAC sanctions jurisdiction and circumvention prohibitions, (2) summarizes recent Russia sanctions, (3) provides a synopsis re sanctions evasion through cryptocurrency, (4) highlights existing US regulatory guidance regarding sanctions evasion through cryptocurrencies, and (5) recommends measures that persons and companies may wish to consider to mitigate the risk of sanctions violations.

This article originally appeared on the website of Winston & Strawn LLP on July 27, 2022.

Authors: Cari Stinebower, Carol Alexis Chen, Dainia Jabaji, Jacob Harding, and Dhruva Krishna

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Region: United States
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