Enforcement Release - Uphold HQ Inc.

Date issued: Mar. 31 2023

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TURBOFAC Commentary (1160 words)

Notes:

1) The Uphold HQ Inc. case is the latest in a string of enforcement cases targeting internet based cryptocurrency exchangers (though this entity deals in cryptocurrency and other assets). Compare Payward, Inc. d/b/a Kraken, Bittrex, Inc., BitPay, Inc and BitGo, Inc.

2) JURISDICTIONAL ISSUES

Uphold HQ Inc. "incorporated in South Carolina with its principal place of business located" in New York [1] , and has at least one UK operating subsidiary [2], which may be the "non-U.S. affiliates" described in the enforcement release.

[1] https://www.dobs.pa.gov/Documents/Enforcement%20Orders/2021/082321%20Uphold%20HQ%20CAO_Redacted.pdf
[2] https://www.prnewswire.com/news-releases/uphold-to-launch-crypto-enabled-cards-across-europe-following-acquisition-of-optimus-cards-uk-301220536.html

For Cuba and Iran, activities of the Uphold HQ Inc. and any owned or controlled foreign entities are directly subject to the prohibitions of the Cuba (515.329) and ITSR (560.215). For...