Key Points

In addition to watching out for customer transactions with the listed addresses, exchanges will likely need to conduct analysis to identify any additional wallets that may be controlled by the Iranian exchangers. Treasury’s move makes it clear that malevolent actors hiding behind digital currency transactions, and those that support these activities, may also find themselves in Treasury’s crosshairs.

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Andrew Jackson Higgins’s reward for his hard work and ingenuity was more than financial—he earned the entire nation’s gratitude. Eisenhower paid him tribute in his 1944 Thanksgiving Day address: “Let us thank God for Higgins Industries, management, and labor which has given us the landing boats with which to conduct our campaign.” If America wants to retain its prosperity and freedom, it will need more patriotic businessmen like Higgins.

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Technological advancements are enabling U.S. adversaries to cause damage disproportionate to the resources deployed in a domain without clearly defined rules of engagement. While Iran does not have the cyber capabilities of China, Russia, or North Korea, Tehran is willing to take greater risks and cause greater destruction. The Islamic Republic cannot match Washington’s capabilities on the traditional military battlefield nor in the virtual world, but its hackers can still do serious damage. If U.S. decision makers begin to initiate more robust defensive initiatives with allies and the private sector, and simultaneously prepare cyber and kinetic countermeasures, Washington may well prevent a more devastating cyber battle in the future.

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Despite last week’s announcement, there is a related risk that FATF appears unready to address: the future possibility that central banks will develop digital currencies and approve them as legal tender. In fact, many governments are exploring prospects for “central bank digital currencies” in the coming years. As FATF’s recommendations currently stand, such digital currencies would appear to fall under the same regulatory rules for conventional fiat currencies. However, the concrete appearance of a government digital currency would likely raise unforeseen questions and challenges. FATF and financial regulators around the world will have to keep an eye on this potential development, even if it remains distant for now.

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Before the U.S. can do that, it first needs to do two things: One, the U.S. government should assess the status of blockchain technology development by key U.S. adversaries like Russia, China, Iran, and North Korea. Second, America should develop a National Digital Currency and Blockchain Strategic Plan that maps out ways to ensure that American firms, talent, and government agencies stay ahead of the potential cryptocurrency curve. Recently, U.S. Federal Reserve governor Lael Brainard expressed her confidence that the dollar will remain the world’s dominant reserve currency. Let’s hope such sentiments do not lead to complacency. If they do, the cat and mouse game could instead turn into the fable of the tortoise and the hare.

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Events

EVENT: The Battlefield of Today and Tomorrow: Cyber-Enabled Economic Warfare

November 13, 2018 | 10:00

Projects