OFAC Sanctions California-Based BitGo, Inc., For Cuba Digital Wallet Management Service
/Enforcement Release: December 30, 2020 OFAC Enters Into $98,830 Settlement with BitGo, Inc. for Apparent Violations of Multiple Sanctions Programs Related to Digital Currency Transactions BitGo, Inc. (“BitGo”), a technology company based in Palo Alto, California, that implements security and scalability platforms for digital assets and offers non-custodial secure digital wallet management services, has agreed to remit $98,830 to settle its potential civil liability for 183 apparent violations of multiple sanctions programs (the “Apparent Violations”).
As a result of deficiencies related to BitGo’s sanctions compliance procedures, BitGo failed to prevent persons apparently located in the Crimea region of Ukraine, Cuba, Iran, Sudan, and Syria from using its non-custodial secure digital wallet management service. BitGo had reason to know that these users were located in sanctioned jurisdictions based on Internet Protocol (IP) address data associated with devices used to log into the BitGo platform. At the time of the transactions, however, BitGo failed to implement controls designed to prevent such users from accessing its services. OFAC determined that BitGo did not voluntarily self-disclose the Apparent Violations and that the Apparent Violations constitute a non-egregious case.
This action emphasizes that OFAC sanctions compliance obligations apply to all U.S. persons, including those involved in providing digital currency services. As part of a risk-based approach, OFAC encourages companies that provide digital currency services to implement sanctions compliance controls commensurate with their risk profile.
