Once a U.S. person determines that they hold virtual currency that is required to be blocked pursuant to OFAC's regulations, the U.S. person must deny all parties access to that virtual currency, ensure that they comply with OFAC regulations related to the holding and reporting of blocked assets, and implement controls that align with a risk-based approach. (See 31 C.F.R. 501.603 for reporting requirements related to blocked and unblocked property.)
For example, a U.S. virtual currency company that maintains multiple virtual currency wallets in which a blocked person has an interest may choose to block each virtual currency wallet or opt to consolidate wallets that contain blocked virtual currency (similar to an omnibus account). Each of these solutions is consistent with OFAC requirements for holding blocked property, so long as there are controls that will allow the virtual currency to be unblocked and returned to its owner only pursuant to an OFAC authorization or when the legal prohibition requiring the blocking of the virtual currency ceases to apply. For those with questions about blocking funds related to traditional funds transfers, see FAQ 32.
U.S. persons are not obligated to convert the blocked virtual currency into traditional fiat currency (e.g., U.S. dollars), and are not required to hold such blocked property in an interest-bearing account. Blocked virtual currency must be reported to OFAC within 10 business days, and thereafter on an annual basis, so long as the virtual currency remains blocked. Questions about whether a transaction should be blocked may be directed to OFAC at 202-622-2490 or OFAC_Feedback@treasury.gov. Owners of blocked virtual currency may also contact OFAC regarding the treatment of their virtual currency pursuant to this guidance.