OFAC’S SMALL-ISH PENALTY AGAINST KRAKEN

OFAC issued an enforcement action against the U.S.-based crypto exchange Kraken.

What is perhaps most striking is how this matter is much more like the run-of-the-mill OFAC enforcement action against a mature financial institution, and not a start up.  Key language from OFAC:  “This case also demonstrates the value of a company implementing robust remedial measures after becoming aware of a potential sanctions issue, including the deployment of blockchain analysis tools and compliance-related training on blockchain analytics, as well as committing to future sanctions compliance investments.”

Enforcement action is here:  https://home.treasury.gov/system/files/126/20221128_kraken.pdf

Coindesk coverage is here:  https://www.coindesk.com/policy/2022/11/28/crypto-exchange-kraken-settles-case-with-us-treasury-over-serving-customers-in-iran/?utm_source=Sailthru&utm_medium=email&utm_campaign=First%20Mover%20November%2029%2C%202022&utm_term=First%20Mover