Earlier quoted context omitted.
The sanctions go a little bit further than that though. Financial institutions are not merely blocked from accepting transactions from the IP region of North Korea, but actually from doing business with a whole list of companies and individuals with ties to NK. To comply with the sanctions regulation you would need to have a lookup service listing the owner of every wallet and for every transaction you validate, chec…
It was actually ruled in 2014 that virtual currency miners are not money transmitters[0]. [0] https://www.fincen.gov/sites/default/files/news_release/2014...
> The first ruling states that, to the extent a user creates or “mines” a > convertible virtual currency solely for a user’s own purposes, the user > is not a money transmitter under the BSA.
That seems to leave rather a lot of open space IMO. For example, does a POS validator create convertible virtual currency? Clearly. But is it solely for their own purposes? Do they become a money transmitter as soon as they sell their crypto? Also, only part of miner income is the block reward; there are transaction fees as well. Is a miner allowed to accept fees from sanctioned individuals for providing payment validation services?
2014 was forever ago in crypto terms of course, so I can imagine that the viewpoints of regulators have evolved together with the technology.