Yes. OFAC's designation of Nobitex, Wallex, Bitpin, Ramzinex, Aban Tether, or any digital asset exchange pursuant to Executive Order (E.O.) 13902 for operating in the Iranian financial sector means that foreign financial institutions and other non-U.S. persons who transact with these exchanges may also face sanctions under E.O. 13902 or other Iran-related authorities. For example, pursuant to E.O. 13902, OFAC has authority to:
- Designate persons that have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any digital asset exchange designated pursuant to E.O. 13902; or
- Prohibit or impose strict conditions on correspondent account or payable-through account opening or maintenance by foreign financial institutions that have knowingly conducted or facilitated any significant financial transaction for or on behalf of any digital asset exchange designated pursuant to E.O. 13902.
Foreign financial institutions may be exposed to statutory sanctions for engaging in significant financial transactions with any designated Iranian financial institutions, including Nobitex, Wallex, Bitpin, Ramzinex, and Aban Tether, pursuant to the National Defense Authorization Act of Fiscal Year 2012. Please see FAQ 174 for more information.
For more information on Iranian digital asset exchanges being blocked under OFAC sanctions, please see FAQ 1250.