Abstract:California-based crypto exchange CoinList (CLM), which allegedly processed 989 transactions on behalf of users ordinarily resident in Crimea, has agreed to pay $1,207,830 to settle its potential civil liability.

California-based crypto exchange CoinList (CLM), which allegedly processed 989 transactions on behalf of users ordinarily resident in Crimea, has agreed to pay $1,207,830 to settle its potential civil liability.
Facilitating such transactions apparently violated the Office of Foreign Assets Controls (OFAC) Russia/Ukraine sanctions, according to an enforcement release published by the U.S. Department of Treasury on December 13.
The crypto exchanges screening procedures did not capture users who represented themselves as residents of a non-embargoed country but who nevertheless provided an address within Crimea. Specifically, the firm opened 89 accounts for customers who specified “Russia” as their country of residence but provided addresses in Crimea when their accounts were opened.
“Because ”Russia“ was provided in the country-of-residence field in these instances, CLMs screening protocols failed to recognize that ”Crimea“ or a city name in Crimea, provided in another data field, indicated likely residence in Crimea,” reads the enforcement release.
CoinList provided financial services to these users between April 19, 2020, and May 7, 2022, failing to exercise due caution or care for its sanction compliance obligations. The government department said the firm knew or had reason to know it was conducting transactions on behalf of persons who were likely to be ordinarily resident in Crimea.
Similarly, seven months ago, crypto exchange Poloniex agreed to a $7.6-million settlement associated with over 65,000 apparent violations of various sanctions, including those on Crimea.
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