On December 13, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with crypto exchange CoinList for an “apparent violation” of sanctions related to Russia and Ukraine. Over a two-year period until May 2022, CoinList processed 989 transactions totaling $1.25 million from users claiming residence in Crimea, a disputed region annexed by Russia in 2014. While CoinList had compliance procedures, its screening did not detect users who identified as non-embargoed but provided a Crimea address. OFAC listed mitigating factors, including CoinList’s cooperation, lack of prior notices, and remedial actions. The settlement of $1.2 million is less than the violating transactions’ amount, and $300,000 will be suspended pending compliance commitments, invested in sanctions controls. The settlement is a fraction of the $327 million maximum penalty, reflecting non-egregious actions and lack of voluntary disclosure. CoinList, a minor exchange, had a 24-hour volume of $350,000.
By FCCT Editorial Team

