CoinList Markets LLC — $1,207,830 OFAC penalty
OFAC published a $1,207,830 civil penalty against CoinList Markets LLC on 12/13/2023. It is the #93 largest action in OFAC’s 1,052-entry enforcement chart and #10 of the 16 actions published that year.
The record
| Entity, as published by OFAC | CoinList Markets LLC |
|---|---|
| Penalty / settlement amount | $1,207,830 |
| Date published by OFAC | 12/13/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #93 of 1,052 |
| Rank within 2023 | #10 of 16 |
| Share of 2023 penalty total | 0.1% |
| Statutory maximum penalty | $327,306,583 |
| Base penalty | $3,097,000 |
| Voluntarily self-disclosed | No |
| OFAC egregiousness determination | Non-egregious |
| Conduct period cited | April 2020 - May 2022 |
| Sanctions programs named in the release | Russia, Ukraine/Crimea |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $327,306,583. The settled amount of $1,207,830 is 0.4% of that maximum, which OFAC's Enforcement Guidelines tie to factors including voluntary self-disclosure and whether the conduct was egregious.
Primary source
OFAC enforcement release: 20231213_coinlist_settlement.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- Construction Specialties Inc. — $660,954
- Privilege Underwriters Reciprocal Exchange — $466,200
- Godfrey Phillips India Limited — $332,500
- DaVinci Payments — $206,213
- Uphold HQ Inc. — $72,230.32
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