Poloniex, LLC — $7,591,630 OFAC penalty
OFAC published a $7,591,630 civil penalty against Poloniex, LLC on 05/01/2023. It is the #42 largest action in OFAC’s 1,052-entry enforcement chart and #5 of the 16 actions published that year.
The record
| Entity, as published by OFAC | Poloniex, LLC |
|---|---|
| Penalty / settlement amount | $7,591,630 |
| Date published by OFAC | 05/01/2023 |
| Aggregate penalties, settlements or findings | 1 |
| Rank among all published OFAC actions | #42 of 1,052 |
| Rank within 2023 | #5 of 16 |
| Share of 2023 penalty total | 0.5% |
| Apparent violations cited | 65,942 |
| Statutory maximum penalty | $19,692,872,800 |
| Base penalty | $99,237,000 |
| Voluntarily self-disclosed | No |
| OFAC egregiousness determination | Non-egregious |
| Sanctions programs named in the release | Iran, Cuba, Syria, Ukraine/Crimea, Sudan |
Settlement against statutory maximum
OFAC put the statutory maximum civil monetary penalty for this case at $19,692,872,800. The settled amount of $7,591,630 is 0.0% 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: 20230501_poloniex.pdf. This page adds no facts beyond that document and OFAC’s published penalty chart.
Comparable 2023 actions
- 3M Company — $9,618,477
- Nasdaq, Inc. — $4,040,923
- Murad, LLC, and an Individual — $3,509,286
- Swedbank AS (Latvia) — $3,430,900
- Microsoft Corporation — $2,980,265.86
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