Enforcement Release: Interactive Brokers LLC

Date issued: Jul. 14 2025

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TURBOFAC Commentary (807 words)

Notes:

1) This enforcement action is notable for a number of unusual characteristics, including being the first ever enforcement actions involving violations of OFAC's Russia-related new investment prohibition, the prohibitions on certain transactions of entities on the Chinese Military Companies Sanctions list, and Venezuela-related EO 13692.

2) CRIMEA IP

As it relates to OFAC's compliance expectations concerning the Crimea embargo, it is clear that OFAC expects IP-based geoblocking tied to the embargoed area ("IB failed to include Crimea in its IP Blocking List,2 and, from May 2019 to June 2021, IB failed to include IP addresses linked to the major Crimean city of Sevastopol in its IP Blocking List, leading to additional apparent violations.") Similar logic presumably applies to the DNR/LNR embargo, though it is less clear whether IP-based blocking is fully practicable given the...