The Office of Foreign Assets Control has designated which types of high-risk persons or entities in the digital asset ecosystem? (Select Three.)

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has increasingly focused its sanctions authority on high-risk actors within the digital asset ecosystem to combat illicit finance. OFAC has designated state-sponsored hacking groups, such as North Korea's Lazarus Group, for stealing cryptocurrency to fund illicit weapons programs. It has also sanctioned non-compliant virtual currency exchanges, like SUEX and Garantex, for facilitating transactions for ransomware actors, darknet markets, and other sanctioned entities. Furthermore, OFAC has designated cryptocurrency mixers, including Blender.io and Tornado Cash, for their role in laundering stolen virtual currency and obscuring the transaction trail for malicious cyber actors.

D. Software developers: OFAC sanctions illicit entities and their activities, not the profession of software development itself, unless a developer is knowingly part of a designated criminal or state-sponsored enterprise.

E. Credit unions: Credit unions are traditional depository institutions. While they may be exposed to crypto-related risks, they are not a type of high-risk entity within the digital asset ecosystem that OFAC has designated.

F. Central banks: A central bank is a state's primary monetary authority. While a country and its state-owned entities can be sanctioned, this is not a specific category of high-risk actor within the digital asset ecosystem.

1. U.S. Department of the Treasury. (2022, May 6). U.S. Treasury Sanctions Notorious Virtual Currency Mixer Blender.io. [Press Release]. Retrieved from https://home.treasury.gov/news/press-releases/jy0768. (This release explicitly mentions OFAC's designation of a mixer, Blender.io, and its use by the DPRK-state sponsored hacking group, Lazarus Group, to launder stolen cryptocurrency).

2. U.S. Department of the Treasury. (2022, August 8). U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash. [Press Release]. Retrieved from https://home.treasury.gov/news/press-releases/jy0916. (This document confirms the designation of another mixer, Tornado Cash, for laundering proceeds of cybercrimes, including for the Lazarus Group).

3. U.S. Department of the Treasury. (2021, September 21). Treasury Sanctions SUEX OTC Cryptocurrency Exchange for Facilitating Ransomware Payments. [Press Release]. Retrieved from https://home.treasury.gov/news/press-releases/jy0364. (This source provides a clear example of OFAC designating a cryptocurrency exchange for its role in illicit finance).

4. U.S. Department of the Treasury. (2022, April 5). Treasury Sanctions Russia-Based Hydra, World’s Largest Darknet Market, and Ransomware-Enabling Virtual Currency Exchange Garantex. [Press Release]. Retrieved from https://home.treasury.gov/news/press-releases/jy0703. (This release documents the designation of another virtual currency exchange, Garantex, for willfully disregarding AML/CFT obligations).