Another Reason From OFAC For Financial Institutions To Avoid Cuba- The Range Of A Penalty: US$1.2 Million Settlement With US$327.3 Million Potentiality.
/“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 nonegregious.”
“Penalty Calculation and General Factors Analysis The statutory maximum civil monetary penalty applicable in this matter is $327,306,583. OFAC determined that the Apparent Violations were not voluntarily self-disclosed and were non-egregious. Accordingly, under OFAC’s Economic Sanctions Enforcement Guidelines (“Enforcement Guidelines”), the base civil monetary penalty amount applicable in this matter equals the applicable schedule amount, which in this case is $3,097,000. The settlement amount of $1,207,830 reflects OFAC’s consideration of the General Factors under the Enforcement Guidelines.”
