[A4ET8a8uTh0]

Not sure why you are bring downvoted as it is pretty close to Treasury recent FAQ[1] on dusting:

"OFAC is aware of reports following the designation of Tornado Cash that certain U.S. persons may have received unsolicited and nominal amounts of virtual currency or other virtual assets from Tornado Cash, a practice commonly referred to as “dusting.” Technically, OFAC’s regulations would apply to these transactions. To the extent, however, these “dusting” transactions have no other sanctions nexus besides Tornado Cash, OFAC will not prioritize enforcement against the delayed receipt of initial blocking reports and subsequent annual reports of blocked property from such U.S. persons.

For guidance related to filing an initial and annual report of blocked property, please see FAQs 49, 50, and 646, respectively, and 31 C.F.R. § 501.603. Please note that the annual filing requirement for 2022 applies only to persons holding blocked property as of June 30 of this year. Released on 09/13/2022 "

The individuals that got ETH may have some reporting requirements, but OFAC seems to understand it is an effort to make enforcement complicated by design.

[1]https://home.treasury.gov/policy-issues/financial-sanctions/...

[treis]

$400,000 worth of eth isn't "nominal" though.

[kube-system]

The treasury is using "nominal" to describe what the word "dusting" means... it is when someone sends small amounts of sanctioned crypto to a bunch of accounts. This is from an FAQ article that confirms: yes, even small amounts are in violation of sanction laws.

If a $5 transaction breaks the law, then $400,000 also does.

[A4ET8a8uTh0]

Yeah and that is why I think they may end up having to report it to OFAC anyway and keep submitting annual updates. As always, at this amount, I would consider asking a specialized attorney ( although, ever since Russia invaded Ukraine, they had their hands full ).

[bee_rider]

I think they are being downvoted because "not touching it" is not the end of the required action. It is the first step toward getting in compliance.

The FAQ is saying "don't freak out, here are some forms to fill out to start straightening out this mess" I think.