2022 Trust Forum Presentations

INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL

Bittrex

• Crypto exchanger founded in 2014 • No sanctions or anti-money laundering compliance programs - no internal controls to screen customers or transactions • OFAC fine - over $24.2M for over 116,000 transactions totaling over $263.4M for apparent violations of Ukraine, Cuba, Iran, Sudan, and Syria sanctions programs • As in most penalty cases, the financial institution got off easy; for this case o Statutory maximum civil monetary penalty = over $35.7B o Not voluntarily self-disclosed but non-egregious = a base amount of $485.6M o Bittrex benefited from further mitigating factors that got them down to the $24.2M settlement amount • OFAC’s largest virtual currency action to date and first parallel action with FinCEN o FinCEN fined them over $29M for willful violation of the BSA - failure to maintain an effective AML program and file SARs

11/3/2022

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INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL

Nodus

• International financial entity located in Puerto Rico • Violations of the Venezuelan Sanctions Regulations (VSR) and the Reporting, Penalties and Procedures Regulations (RPPR) o VSR violations - voluntary self-disclosure of three unlicensed transactions in which an SDN had an interest ƒ processed the securities redemption without obtaining a license o RPPR violations - failure to maintain full and accurate records on blocked property and inaccurate reporting of the blocked property • OFAC determined that the appropriate administrative action in this matter was a finding of violation in lieu of a civil monetary penalty

11/3/2022

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