When Worlds Collide 
A San Francisco-based crypto exchange has reached an agreement with the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to settle its potential civil liability for violating US sanctions related to Russia and Ukraine.
In a new enforcement release, the OFAC says that CoinList Markets (CLM) has agreed to pay over $1.2 million as a settlement for processing hundreds of transactions that violated the government’s embargo policies.
The agency says the exchange complied with some of the sanction measures including denying access to users with IP addresses in prohibited jurisdictions and rejecting applications from users who presented IDs from and provided addresses in sanctioned nations.
Unfortunately, CLM’s screening procedures fell short. The OFAC says some users who reside in Russia managed to open an account after providing addresses in Crimea.
“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.”
CLM faces up to $327,306,583 in statutory civil monetary penalty but the OFAC says the settlement amount reflects several considerations, which include the exchange undertaking remedial measures to improve compliance.
“In view of the individual facts of this case, including CLM’s financial circumstances, $300,000 of the settlement amount will be suspended pending satisfactory completion of CLM’s compliance commitments as agreed to by CLM as part of this settlement. Moreover, as partial satisfaction of the settlement amount, CLM has also agreed to invest $300,000 in additional sanctions compliance controls, including with respect to enhanced screening controls and additional compliance staff.”
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