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ARTICLE · 22 MAY 2023

Sanctions Can Be An Acquired Problem

Barnes, Richardson & Colburn
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There is always a certain amount of risk associated with starting a new company. There are so many business operations to put in place even before business starts.

United StatesInternational Law
Marvin E. McPherson
Marvin E. McPherson

There is always a certain amount of risk associated with starting a new company. There are so many business operations to put in place even before business starts. Those risks are only magnified when a start up is acquired. The sanctions experience of Poloniex, LLC makes this clear in about 7.5 million ways.

Poloniex, an online trading and settlement platform, will pay $7,591,630 for potential civil liability for 65,942 apparent violations of multiple sanctions programs. Poloniex's violations included failing to stop customers from sanctioned jurisdictions from engaging in online digital asset-related transactions. The settlement amount reflects OFAC's determination that Poloniex's apparent violations were not voluntarily self-disclosed and were not egregious.

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