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ARTICLE · 29 NOVEMBER 2023

Binance's Paper Compliance Program Crumples Under OFAC Scrutiny In Largest OFAC Settlement In History

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On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance.

United StatesTechnology
Reid Whitten
Reid Whitten
Jordan Mallory
Jordan Mallory
Fatema Merchant
Fatema Merchant
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On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger comprehensive settlement with the Department of Justice, FinCEN, and the CFTC, totaling over $4 billion. OFAC found that Binance had allowed 1.6 million transactions in violation of multiple sanctions regimes while Binance's C-Suite was complicit. Binance's blunders that led to this enforcement action highlight the importance of management commitment to compliance programs.1

This penalty is news in and of itself, but the news is not niche or limited to cryptocurrencies or the exchanges on which they are traded. In going after the largest cryptocurrency exchange in the world, OFAC is sending a clear message to any company involved in FinTech: you cannot hide behind your algorithms or paper compliance programs. FinTech companies cannot claim that,

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