CoinList Markets LLC is a currency exchange. When its customers open accounts, there is a Know-Your-Customer (KYC) process which requires individual applicants to provide, among other things, their country of residence and address. CoinList maintained several sanctions compliance measures, including screening new and existing customers against Office of Foreign Assets Control (OFAC) and other sanctions lists. By spring of 2021, CoinList’s onboarding protocols also included an automated process through which an application was meant to…
Bittrex, Inc. is a company based in Bellevue, Washington that provides an online virtual currency exchange and hosted wallet services. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) alleged that Bittrex violated programs for sanctions against Cuba, Iran, Sudan, and Syria, as well as Ukraine-related. More specifically, according to OFAC, Bittrex failed to prevent persons apparently located in the sanctioned jurisdictions from using its platform to engage in over $263 million worth…
October is National Cybersecurity Awareness Month. Thus, on October 1, 2020, the U.S. Department of the Treasury’s Office of Terrorism and Financial Intelligence issued a pair of advisories to assist U.S. individuals and businesses in efforts to combat ransomware scams and attacks, which continue to increase in size and scope. As Treasury explained, anti-money laundering and sanctions regulations implemented and enforced by Treasury’s Office of Terrorism and Financial Intelligence may have implications for persons involved in…
What’s changed The U.S. Government is considering adding digital currency addresses affiliated with individuals and entities identified to the List of Specially Designated Nationals and Blocked Persons (“SDN List”). This would put U.S. persons on notice that doing business with those digital addresses may be prohibited, increasing compliance considerations for businesses delving into the world of virtual currency. What it means for you On March 19, 2018, the U.S. Office of Foreign Assets Control (“OFAC”)…
OFAC, the Office of Foreign Assets Control, is the financial intelligence and enforcement agency of the U.S. Treasury Department that administers and enforces economic and trade sanctions. On March 19, 2018, the OFAC updated its FAQs to include a section on virtual currency. In the new section, OFAC provides guidance about the various money laundering and terrorist financing risks associated with virtual currency, and goes on to state that it will use sanctions to “fight…