California technology company agrees to settle various sanctions violations

Company agrees to settle various sanctions violations

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today announced a settlement with a technology company based in Palo Alto, California. The company’s business includes implementing security and scalability platforms for digital assets and to offer non-custodial secure “digital wallet” management services.


The company agreed to pay almost $99,000 to settle its potential civil liability for 183 apparent violations of multiple sanctions programs.

As noted in an OFAC release [PDF 244 KB], the apparent violations were processed between March 10, 2015, and December 11, 2019, on behalf of persons located in the Crimea region of Ukraine, Cuba, Iran, Sudan or Syria that were using the company’s non-custodial secure digital wallet management service. The OFAC release explains that because of deficiencies related to the company’s sanctions compliance procedures:

  • The company 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.
  • The company had reason to know that these users were located in sanctioned jurisdictions based on the internet protocol (IP) address data associated with devices used to log in to the company’s platform.

The OFAC determined that the company did not voluntarily self-disclose the apparent violations and that these apparent violations constituted a “non-egregious case.”

For more information on this topic or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094

Irina Vaysfeld
T: 212-872-2973

Amie Ahanchian
T: 202-533-3247

Christopher Young
T: 312-665-3229

Gisele Belotto
Managing Director
T: 305-913-2779

George Zaharatos
T: 404-222-3292

Andy Doornaert
Managing Director
T: 313-230-3080

Jessica Libby
Managing Director
T: 612-305-5533

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