Enforcement Release - Bittrex, Inc.

Date issued: Oct. 11 2022

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TURBOFAC Commentary (143 words)

Notes:

1) This is the largest payable fine that OFAC has issued since the UniCredit Bank AG case (owed to the high number of transactions processed), but otherwise it does not break new ground as the basis for liability and compliance considerations discussed are very similar to the other cryptocurrency-related enforcement actions, i.e. BitGo, Inc. and BitPay, Inc. Compare also Civil Enforcement Information - Tango Card, Inc., issued just before this action, dealing with internet services provided to presumptively persons "ordinarily resident" in embargoed destinations in light of their IP addresses.

2) Note the reference to "blockchain tracing software to assist in identifying and blocking virtual currency addresses associated with persons potentially identified on OFAC’s SDN List". This appears to be the first statement that OFAC has...