PRINT
Enforcement Release: September 22, 2025
ShapeShift AG Settles with OFAC for $750,000 Related to Apparent Violations of Multiple Sanctions Programs
ShapeShift AG (“ShapeShift”), a digital asset exchange incorporated in Switzerland and operating from Denver, Colorado, has agreed to pay $750,000 to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs. Between December 10, 2016 and October 9, 2018, ShapeShift engaged in digital asset transactions on its exchange platform with users located in Cuba, Iran, Sudan, and Syria. The settlement amount reflects OFAC’s determination that ShapeShift’s apparent violations were non-egregious and not voluntarily self-disclosed. The settlement amount also reflects the fact that ShapeShift is a defunct concern with limited assets that has ceased operations such that it no longer provides digital asset services that could lead to apparent violations. More broadly, this enforcement action highlights the importance for digital asset actors...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) As it relates to the legal basis for this enforcement action, apart from the jurisdictional points discussed below, the enforcement action does not do much in the way of breaking new legal ground. This is one of an increasingly long line of internet based cryptocurrency exchanges that has been penalized for providing services to individuals located in embargoed destinations, where OFAC took IP addresses being linked to sanctioned destinations as sufficient basis on which to conclude that the entity fined had provided services to a person in or ordinarily resident in such destination. Compare e.g. Enforcement Release: CoinList Markets LLC.
2) The statement in the “Compliance Considerations” section concerning the “incorporat[ion of] sanctions compliance considerations at the development and beta testing stages” appears to be novel.
3) ShapeShifting on the Definition of “U.S. Person”?
This Enforcement Release appears to break...