Enforcement Release - Airbnb Payments, Inc.

Date issued: Jan. 03 2022

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TURBOFAC Commentary (2444 words)

Notes:

1) THE UNADDRESSED CRIMEA-RELATED VIOLATIONS

Airbnb, Inc. is a major provider of online travel accommodation services, generally acting as an intermediary between persons reserving property for short-term stays and the owners/managers of such properties (“hosts”). “As of September 30, 2020, [it] had over 4 million hosts around the world, with 86% of hosts located outside of the United States.” https://www.sec.gov/Archives/edgar/data/1559720/000119312520294801/d81668ds1.htm. In a Nov. 2020 SEC filing, Airbnb disclosed the following:

Since July 2019, we conducted an internal review and have been holding related discussions with OFAC regarding certain user activity on our platform that may have been inconsistent with our policies and the requirements of U.S. sanctions laws. The scope of this review included activity by users in certain countries and territories that were or are the target of U.S. sanctions laws. In July 2020, OFAC issued to us...