Absent authorization from OFAC, U.S. persons are prohibited from engaging in transactions related to, providing financing for, and otherwise dealing in any “digital currency, digital coin, or digital token” that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018. OFAC would consider license applications involving Government of Venezuela-issued “digital currency, digital coin, or digital token” on a case-by-case basis and base licensing determinations on the facts and circumstances of the particular application.
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