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Treasury

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today announced a settlement with BitPay, Inc., a private company based in Atlanta, Georgia, that offers a payment processing solution for merchants to accept digital currency as payment for goods and services. BitPay agreed to remit USD507,375 to settle its potential civil liability for 2,102 apparent breaches of multiple sanctions requirements. We have edited the relevant media material and commented on it.

The case provides fascinating background as US PoTUS Biden undertakes a wide-ranging review of Trump-era regulations including sanctions. Much will turn on whether such sanctions are "revoked" or "repealed" or, even, just "cancelled." It also draws attention to "know your customer's customer."

Any business that does business in or via the USA, including doing business in US Dollars is subject to US sanctions law. The USA frequently punishes foreign businesses which it says has breached its sanctions law. While the media focus is usually on action against UK and EU banks, the simple fact is that successful actions have been brought against, even, individuals buying and selling goods via eBay. So, when the US Treasury says "this is how to design your compliance system," it makes a great deal of sense to pay attention. Yesterday, that's what it said. So pay attention.

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