OFAC has designated 2 Iranian nationals, Ali Khorashadizadeh and Mohammad Ghorbaniyan, “who helped exchange digital currency (bitcoin) ransom payments into Iranian rial on behalf of Iranian malicious cyber actors involved with the SamSam ransomware scheme”. For the first time, OFAC has also publicly identified 2 digital currency addresses associated with these 2 individuals, in which over 7000 bitcoin transactions (worth millions of US dollars) were processed through. These cyber-related designations were made pursuant to Executive Order 13694, which imposes US asset freezes and travel bans, and could subject others to secondary sanctions if they engage in transactions with the 2 listed individuals. See OFAC Notice, US Treasury Press Release, and Two New Digital Currency-Related FAQs.
Maya Lester QC is a senior barrister (Queen’s Counsel) at Brick Court Chambers with a wide-ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. The legal directories say she is the...See profile for Maya Lester QC >