BitGo's October 2021 $98K OFAC settlement over apparent violations involving sanctioned jurisdictions - the custody-layer lessons.
In October 2021, BitGo settled with OFAC for $98,125 over apparent violations involving users in comprehensively sanctioned jurisdictions (Iran, North Korea, Syria, Cuba, Crimea).
OFAC found BitGo's digital asset custody platform processed transactions for users in sanctioned regions. The relatively low settlement reflected the company's cooperation and the violation set.
Even a small settlement is an enforcement action - the pattern is the same: screening that did not run before transactions settled. For agents, the custody layer is one more rail where the screen must run first.
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