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The way I understand it, you are required to comply with OFAC and other Treasury programs in any transaction you make.

Some transactions aren't that risky, because people with bigger pockets have validated it already (generally between US bank accounts). But once you get outside that (like, international, or bitcoin) the requirements to prove that you're paying attention get Hard.

If you're HSBC, that's not a problem. But for everyone else...



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