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