Enforcement Release: December 16, 2025
Exodus Movement, Inc. Settles with OFAC for $3,103,360 for Apparent Violations of Iran-related Sanctions Regulations
Exodus Movement, Inc. (“Exodus”), a U.S. financial technology company, has agreed to pay $3,103,360 to settle its potential civil liability for 254 apparent violations of sanctions on Iran administered by the Office of Foreign Assets Control (OFAC). In particular, Exodus provided customer support services to users in Iran which, in certain instances, helped such users access third party digital asset exchanges through Exodus’s proprietary wallet software. In some instances, while aware of U.S. sanctions, Exodus staff recommended that these users obscure their location in Iran using Virtual Private Networks (VPNs) to avoid the sanctions compliance controls implemented by such exchanges. The settlement amount reflects the determination by OFAC that the apparent violations were not voluntarily disclosed and that 12 of the 254 apparent violations were egregious,...
1) From a factual standpoint, this is a first-of-its-kind enforcement action insofar as the entity fined did not actually “process any digital asset exchange transactions,” but instead existed to facilitate transactions performed by third parties. Accordingly, OFAC’s “service” (560.204-based) penalties were styled as not as the provision of financial services per se, but the provision of customer support services (which then resulted in the provision of financial services by third parties).
2) The Enforcement Release is notable for the way in which it distinguishes between egregious and non-egregious violations (very rare in the context of a single enforcement release), where the egregious violations entailed the USP having “recommended the use of VPNs” where such “recommendations ultimately enabled [Iranian] users to continue accessing Exchange A’s services via Exodus Wallet by altering the users’ IP address and obscuring...