The U.S. Treasury's OFAC has expanded its Iran sanctions regime to explicitly include cryptocurrency transactions, alongside gold, shipping, and technology sectors. The action adds new designated entities and wallet addresses to the SDN list and signals elevated enforcement focus on crypto as a sanctions-evasion vector. This represents one of the broader crypto-specific sanction expansions since the Tornado Cash designations.
For the Crypto Repo desk, the risk is operational: any counterparty or wallet with Iran-nexus exposure flowing through a repo transaction creates OFAC liability. Armada's Fireblocks custody setup should have automated blockchain analytics integrated to flag SDN-listed addresses at the point of settlement. Legal counsel should review whether current onboarding documentation and transaction monitoring procedures are sufficient under the expanded designation scope.