The Legit Ledger Episode 5: Cryptocurrency Sanctions with Reid Whitten and Gabe Khoury


In this episode of The Legit Ledger, Sheppard Mullin attorneys Reid Whitten and Gabe Khoury discuss cryptocurrency sanctions, including the role of the OFAC, the consequences of engaging in an unauthorized transaction, risk mitigation strategies for avoiding unauthorized transactions, and more.

About Reid Whitten

Reid Whitten is the Managing Partner of Sheppard Mullin's London office, where his practice focuses on international trade regulations and investigations. He shares his time serving clients out of the Washington, D.C. office and is also Leader of the firm’s CFIUS Team. In the areas of economic sanctions, export and defense exports, CFIUS, anti-corruption and tariffs, Reid supports clients in detecting and addressing potential compliance issues as well as conducting investigations and defending against enforcement actions. He also advises on U.S. anti-dumping, anti-money laundering, and anti-boycott regulations. Reid is recognized as a thought leader on cross-border business regulations and serves as an Adjunct Professor of Law at the New College of the Humanities in London, the Université Catholique de Lille in France. and Wake Forest University in the U.S. He is also a member of Chatham House, the UK's Royal Institute of International Affairs.

About Gabe Khoury

Gabe Khoury is an associate with the Corporate Group in Sheppard Mullin's Washington, D.C. office. As Lead Associate of the Blockchain and Digital Assets team, he handles regulatory compliance issues relating to the use of blockchain technology, social media, Web3.0, video games, online gambling, virtual goods and currency, social tokens, decentralized autonomous organizations, decentralized exchanges, cybersecurity, privacy, Esports, the metaverse, money transmission, financial technologies, NFTs, and artificial intelligence. Gabe holds certifications in NFT technology, Metaverse Technologies, and Blockchain Law from the Blockchain Council.

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What We Discussed in This Episode:

  • What is the Office of Foreign Assets Control or OFAC?
  • What is the SDN list? Where can it be found? What does it mean to be on the SDN list?
  • Has OFAC issued any crypto-specific guidance?
  • What possible consequences might a U.S. resident face for engaging in unauthorized transactions or dealing with sanctioned individuals or jurisdictions?
  • What advice do you have for anyone who's engaged in an unauthorized transaction due to an honest mistake?
  • Can you provide a brief background on the first-ever OFAC sanction on a virtual currency mixer?
  • What is a blender, aka a virtual currency mixer?
  • What exactly does it mean to be sanctioned?
  • Are there any risk mitigation strategies for avoiding unauthorized transactions?
  • What practical guidance do you have for individuals and entities concerned about OFAC sanctions while working in the crypto space?

Resources Mentioned:

Office of Foreign Assets Control - Sanctions Programs and Information

Specially Designated Nationals And Blocked Persons List (SDN) Human Readable Lists

"The Crypto Enthusiast and The Regulator: What OFAC is, Could Be, and Should Be Doing to Regulate CryptoCurrencies"

Contact Information:

Reid Whitten

Gabe Khoury

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This podcast is for informational and educational purposes only. It is not to be construed as legal advice specific to your circumstances. If you need help with any legal matter, be sure to consult with an attorney regarding your specific needs.





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