This week the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced that it had reached a settlement with Kraken, a U.S.-based cryptocurrency exchange. The settlement is related to apparent violations of the Iranian Transactions and Sanctions Regulations. The settlement includes an agreement by Kraken "to invest an additional $100,000 in certain sanctions compliance controls." According to an OFAC enforcement release, the apparent violations were "due to Kraken's failure to timely implement appropriate geolocation tools," which permitted "users who appeared to be in Iran [to engage] in virtual currency transactions on Kraken's platform." OFAC's enforcement release provides further details on the apparent violations and OFAC's considerations and analysis.

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