@jpkoning i'm not sure your piece addresses how ZCash is very different from base-layer protocols like ETH or BTC. with ETH/BTC, transactions can be pseudonymous, but they're public and so traceable with elbow grease. OFAC can sanction ZCash addresses all it wants, but for "shielded" transactions, they have no way to observe violations, let alone trace them.
there's reason to treat ZCash (maybe Monero) differently than ETH/BTC. That OFAC hasn't demands some explanation.