Trading Platform Settles OFAC Charges for Cuba, Iran and Venezuela Sanctions Violations

A multi-asset digital trading platform agreed to pay $72,230.32 to settle its potential civil liability for apparent sanctions violations after processing 152 transactions for customers who were either (i) located in Iran or Cuba or (ii) were employees of the Government of Venezuela.

In an Enforcement Release, OFAC found that the trading platform failed to conduct diligence on customers who provided information indicating potential sanctions risks and had knowledge that it was processing payments for individuals in sanctioned jurisdictions. As a result, OFAC said that the trading platform violated:

  • Iran Transactions and Sanctions Regulations and Cuban Assets Control Regulations by maintaining accounts for customers who (i) indicated during the onboarding process that they were located in Iran or Cuba or (ii) provided an identification document from a sanctioned jurisdiction; and
  • Venezuela Sanctions Regulations and E.O. 13884 ("Blocking Property of the Government of Venezuela,") by processing transactions for two customers who self-identified as employees of Petroleos de Venezuela S.A. (PdVSA), an entity owned by the Government of Venezuela.

OFAC stated that the trading platform processed a total of 152 transactions amounting in $180,576 for customers in apparent violation of sanctions.

In determining the civil money penalty, OFAC acknowledged that the trading platform self-disclosed the apparent violations which OFAC found to be non-egregious. While the statutory maximum civil monetary penalty application for the apparent violations was $44,468,494, the settlement amount of $72,230 was reached based on the application of OFAC's enforcement guidelines and the various aggravating and mitigating factors identified by OFAC.