Online Trading Platform Settles OFAC Charges for Sanctions Violations

An online trading platform settled OFAC charges for processing digital asset-related transactions in sanctioned jurisdictions.

In an Enforcement Release, OFAC said that the trading platform processed 65,942 digital asset-related transactions that had a total value of $15,335,349 for customers located in sanctioned jurisdictions, despite having knowledge of their location through users’ physical address and IP data. OFAC found that the trading platform implemented a sanctions compliance program one year after beginning operations for new customers, but failed to retroactively screen already existing customers. In addition, the trading platform began monitoring IP address data to identify logins from sanctioned jurisdictions, but did not block identified IP addresses until two years later.

As a result, OFAC found that the trading platform engaged in apparent violations of: Executive Order 13685 ("Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to the Crimea Region of Ukraine"); Cuban Assets Control Regulations; Iranian Transactions and Sanctions Regulations; the now-repealed Sudanese Sanctions Regulations; and Syrian Sanctions Regulations.

To settle the potential civil liability, the trading platform agreed to remit $7,591,630. The settlement amount reflects OFAC’s determination that the trading platform’s violations were not voluntarily self-disclosed but were not egregious.