Yes. Executive Order (E.O.) 13599, as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599 regardless of whether it is listed on OFAC's List of Specially Designated Nationals and Blocked Persons (SDN List). Iranian digital asset exchanges meet the regulatory definition of an "Iranian financial institution" as persons that engage in the business of activities described in section 560.324 of the ITSR.
All property and interests in property of Iranian digital asset exchanges in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked pursuant to section 560.211 of the ITSR and must be reported to OFAC. See FAQ 160 for additional information regarding the sanctions implications of E.O. 13599. For additional information regarding the application of sanctions to digital assets, please see FAQs 559, 560, 561, 562, 563, 594, 646, and 647, as well as OFAC's Sanctions Compliance Guidance for the Virtual Currency Industry.