Coinbase — $50,000,000 OFAC Penalty (2023)
OFAC settled with Coinbase for apparent violations across multiple sanctions programs between 2015 and 2019.
Penalty amount: $50,000,000 · Year: 2023 · Enforcer: OFAC (US Treasury)
What happened
Coinbase was penalized by the Office of Foreign Assets Control (OFAC) in 2023. The case is instructive for any organization handling cross-border payments, crypto transactions, or customer onboarding where sanctioned parties may be present.
Violations cited
- Allowing users from sanctioned jurisdictions to open accounts
- Insufficient transaction monitoring
- Failure to screen against updated SDN list
- Inadequate customer due diligence
Lessons for compliance teams
- Pre-onboarding sanctions screening of every user
- Wallet address screening before each transaction
- Periodic re-screening of all customers as lists update
- Transaction-pattern monitoring for sanctions evasion
How this could have been prevented
In nearly every OFAC penalty case, the root cause is the same: inadequate or outdated sanctions screening. The sanctioned parties were on the SDN list at the time — they simply weren't caught. Real-time screening against the current SDN list, with proper name-matching and fuzzy logic, would have flagged most of these transactions before they completed.
Free screening: SanctionsAI provides a free OFAC sanctions screening API. Screen customers, wallets, and transactions against the SDN list in real time. Get API key →