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On November 28, OFAC took action against two Iranian individuals, Ali Khorashadizadeh and Mohammad Ghorbaniyan, for their alleged role facilitating payment ...
On November 28, OFAC took action against two Iranian
individuals, Ali Khorashadizadeh and
Mohammad Ghorbaniyan, for their alleged role
facilitating payment to Iranian cyber hackers involved in the
multi-year SamSam ransomware attacks. More specifically,
Khorashadizadeh and Ghorbaniyan are alleged to have helped exchange
digital currency (bitcoin) ransom payments generated by the scheme
into Iranian rial. OFAC stated that the pair converted millions of
US dollars' worth of digital currency into fiat payments to the
hackers by processing the payments through two digital currency
addresses, which OFAC also identified. The action marked the first
time that OFAC has publically attributed digital currency addresses
to designated individuals.
In announcing the action, OFAC emphasized that
"[r]egardless of whether a transaction is denominated in a
digital currency or traditional fiat currency, OFAC compliance
obligations are the same." OFAC also published updated
guidance pertaining to compliance requirements for digital
currencies, including instructions for blocking digital currency
belonging to SDNs.
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