By ยท ยท last updated 2026-08-08
EtherDelta ($450K), BitGo ($98K), BitPay ($507K) - the enforcement actions that defined DeFi, custody, and merchant payments. What each one teaches.
Binance's $968M dominates the headlines, but the enforcement record that shaped crypto compliance is in the smaller cases. Three settlements defined the rules for DeFi, custody, and merchant payments.
The first enforcement action against a DeFi platform. OFAC found EtherDelta failed to screen and processed transactions involving sanctioned users. The lesson: a protocol operator carries the obligation, and code does not waive it. Full case →
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BitGo's custody platform processed transactions for users in sanctioned jurisdictions. The lesson: the custody layer is one more rail where the screen must run first. Full case →
BitPay processed merchant payments for users in embargoed regions. The lesson: a merchant payment path is the same shape as an agent payment path - geography screening catches what wallets and names miss. Full case →
Every settlement traces to screening that did not run before transactions settled. The amounts scale with volume - which is exactly why agents need the screen in the payment path, not after it.
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