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Enforcement Release: December 13, 2023
OFAC Settles with CoinList Markets LLC for $1,207,830 Related to Apparent Violations of the Ukraine-/Russia-Related Sanctions Regulations
CoinList Markets LLC (“CLM”), a San Francisco, California-based virtual currency exchange, has agreed to pay $1,207,830 to settle its potential civil liability arising from processing 989 transactions on behalf of users ordinarily resident in Crimea between April 2020 and May 2022, in apparent violation of OFAC’s Russia/Ukraine sanctions. The settlement amount reflects OFAC determination that CLM’s apparent violations were not voluntarily self-disclosed and were non-egregious.
Description of the Apparent Violations
CLM, a money services business founded in 2017, allows users to buy, sell, and otherwise trade in crypto tokens and other crypto assets. CLM acts primarily as an intermediary among its users to buy, sell and convert various cryptocurrencies. To do so, users open an account and digital wallet with...
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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.