In video game economies, players spend real money on digital assets, such as in-game items like clothes and weapons, or virtual “money” like “gold” and “coins.” These economies are comparable in size to other large-scale digital economies, such as cryptocurrency. And digital assets in these economies may have substantial value. Although most video game economies are designed to restrict converting digital assets back into real money, demand has led to the creation of unofficial third-party marketplaces and other outlets for trading those digital assets. Because of this development, video game economies may pose money laundering and sanctions evasion risks that current law does not fully address. This article argues that U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has existing authority to address these risks. The OFAC could encourage online gaming platforms to adopt a risk-based compliance model that mitigates potential adverse effects on casual (and anonymous) play. This approach would be more tailored to the realities of the video game industry than imposing banking-style rules on all players.
