U.S. Treasury announces settlements with virtual currency exchange for violations of AML and sanctions laws

Largest settlements in U.S. Treasury Department history

U.S. Treasury announces settlements with virtual currency exchange

The U.S. Department of the Treasury today announced the largest settlements in history with a virtual currency exchange for violations of the Bank Secrecy Act (BSA) and apparent violations of multiple sanctions programs.

According to the Treasury release, the violations include failure to implement programs to prevent and report suspicious transactions with terrorists, ransomware attackers, money launderers, and other criminals, as well as matching trades between U.S. users and those in sanctioned jurisdictions like Iran, North Korea, Syria, and the Crimea region of Ukraine. 

OFAC’s settlement agreement

Today’s OFAC release explains that:

  • The virtual currency exchange—a Cayman Islands company—settled for approximately $968 million for over 1.6 million apparent violations of multiple sanctions programs.
  • Between 2017 and 2022, the virtual currency exchange engaged in the exportation of goods and services from the United States, or by U.S. persons, to users located in sanctioned jurisdictions or blocked persons and caused U.S. persons to engage in transactions with users in those sanctioned jurisdictions or blocked persons. 
  • OFAC determined that these apparent violations were egregious and were not voluntarily self-disclosed.

FinCEN’s settlement agreement

Today’s FinCEN release explains that:

  • FinCEN took “unprecedented action” to hold the virtual currency exchange accountable for willful violations of the Bank Secrecy Act and its implementing regulations.
  • FinCEN’s consent order assesses a civil money penalty of $3.4 billion, imposes a multi-faceted five-year monitorship overseen by FinCEN, and requires significant compliance undertakings, including undertakings to ensure a complete exit of the company from the United States.


For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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