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If they’re holding USDs they are bound to US regulations.


What is this statement based on?

Plenty of sovereign nations (and individuals in those countries) hold reserves of USD and the US has no authority over them.


You’re right. I thought these would apply internationally but it seems like it’s only if one of the party is a US citizen: https://www.jdsupra.com/post/contentViewerEmbed.aspx?fid=f66...

At least for ofac




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