The OverRuled: Sanctions Module has been updated with the following actions:
- 21 Nov 2023 - Binance Holdings Limited - USD $968,618,825
Between August 2017 and October 2022, Binance Holdings Limited ("Binance"), the world's largest virtual currency exchange, matched and executed virtual currency trades on its online exchange platform between U.S. person users and users in sanctioned jurisdictions or blocked persons. Although Binance took steps to project an image of compliance, including by misleading third parties about its controls, senior Binance management knew of and permitted the presence of both U.S. and sanctioned jurisdiction users on its platform, and did so despite understanding that Binance's trade matching algorithm could cause violations of OFAC-administered sanctions programs due to the presence of U.S. users on the platform. In addition to disregarding known sanctions risks, Binance management also took steps to undermine its own compliance function, encouraging users to circumvent the company’s own ostensible controls.
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