On July 15, the Office of Foreign Assets Control (OFAC) imposed sanctions on FirstVPN, signaling a shift in crypto enforcement towards the infrastructure stack. This move indicates that regulatory scrutiny is not limited to tokens but also encompasses the underlying infrastructure supporting cryptocurrency transactions. For compliance teams at CASPs and exchanges, this development matters as it highlights the need for enhanced due diligence and screening of service providers and infrastructure partners. A practical takeaway is that institutions should review their vendor risk management protocols to ensure they are adequately monitoring and reporting potential sanctions risks associated with their infrastructure providers. This is general educational information, not legal advice.
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