Enforcement Release: CoinList Markets LLC

Date issued: Dec. 14 2023

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TURBOFAC Commentary (120 words)

Notes:

Compare the other cryptocurrency exchange service providers whose enforcement releases feature Crimea-related violations (e.g. Enforcement Release: Poloniex, Enforcement Release - Bittrex, Inc., Enforcement Release - BitPay, Inc., Enforcement Release - BitGo, Inc.), and note that a major distinction between this one and the others is that OFAC suggests that screening software should be set such that every (or at least many) cities in Crimea yield screening hits, even where the "country" is listed as Russia. As a statement on the notion of a "reason to know," this enforcement action has implications for all Crimea and DNR/LNR-related compliance (i.e. where the “country” is not comprehensively embargoed). Otherwise, the substance of this enforcement release appears to track the similar cryptocurrency ones.