Payward, Inc. (“Kraken”) — $362,158.70 OFAC penalty
OFAC published a $362,158.70 civil penalty against Payward, Inc. (“Kraken”) on 11/28/2022. It is the #157 largest action in OFAC’s 1,052-entry enforcement chart and #8 of the 14 actions published that year.
The record
| Entity, as published by OFAC | Payward, Inc. (“Kraken”) |
|---|---|
| Penalty / settlement amount | $362,158.70 |
| Date published by OFAC | 11/28/2022 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #157 of 1,052 |
| Rank within 2022 | #8 of 14 |
| Share of 2022 penalty total | 0.8% |
| Statutory maximum penalty | $272,228,964 |
| Base penalty | $840,288.55 |
| Voluntarily self-disclosed | Yes |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran, Ukraine/Crimea |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $272,228,964. The settled amount of $362,158.70 is 0.1% 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: 20221128_kraken.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2022 actions
- CFM Indosuez Wealth — $401,039
- American Express National Bank — $430,500
- Banco Popular de Puerto Rico — $255,937.86
- Newmont Corporation — $141,442
- Tango Card, Inc. — $116,048.60
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