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> if you’re not in the US, not transacting with someone that is and not with anyone on their sanctions list?

And not in a country that extradites to the U.S., or every planning on going through one. Or using U.S. dollars. Or the currencies of its allies.

This is OFAC. Violating its sanctions is akin to doing business with North Korea or Iran. People do it. But you're going to have a different lifestyle.



> And not in a country that extradites to the U.S., or every planning on going through one. Or using U.S. dollars. Or the currencies of its allies.

Only US persons faces criminal prosecution for sanction violations. Non-US persons face secondary sanctions which is still quite serious penalty.


> only US persons faces criminal prosecution for sanction violations

Not true. Anyone in U.S. jurisdiction faces criminal prosecution. That's a far more expansive set than U.S. persons.


I didn’t see that.

Could a Canadian continue to pay their Canadian neighbour for mowing their lawn through tornado or not?


> Could a Canadian continue to pay their Canadian neighbour for mowing their lawn through tornado or not?

They’d get arrested and lose all their money. So in practice, no.


Under which term of the sanction?


> which term of the sanction?

What? These powers emanate from trading with the enemy and other wartime acts [1]. Violating sanctions can literally authorise U.S. military countermeasures.

Tornado helped Pyongyang finance its missile programme. That’s the colour of law we’re discussing.

[1] https://en.m.wikipedia.org/wiki/Office_of_Foreign_Assets_Con...


And I read their press release and quoted their entire "Sanction Implications" section, and it basically says you can't use Tornado if you're a US person or dealing with US assets and you can't use it if you're dealing with someone on OFAC's sanction list.

Which seems to leave a lot of transactions, like a non-sanctioned non-American paying another non-sanctioned non-American for something with mixed crypto entirely off of US soil. The sanction doesn't appear to apply against that.


It doesn't matter. It's generally enough in diplomatic channels that if an American could access a service, the U.S. will treat it as if it has been used by one.

As I understand, this is why an American in Europe can have a hard time creating an account. In order to operate in that country without triggering treaty clauses, there has to be a technical or process measure to keep U.S. customers abroad out. Otherwise that state is obligated by treaties to consider that business in breach of U.S. sanctions.


> a non-sanctioned non-American paying another non-sanctioned non-American for something with mixed crypto entirely off of US soil

Sure. You will be a fugitive from American law for the rest of your life. But plenty of people make a living in that category.


For breaking which law or term of the sanction? It genuinely seems like OFAC sanctions only apply here when dealing with listed Persons or any US national on either side of a Tornado transaction.




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