By
Kyle Brasseur2023-11-06T20:25:00
DaVinci Payments, a financial services firm which manages prepaid reward card programs, agreed to pay approximately $206,000 as part of a settlement with the Treasury Department’s Office of Foreign Assets Control (OFAC) addressing alleged sanctions violations across four countries.
DaVinci voluntarily self-disclosed the matter, which OFAC deemed non-egregious. The agency’s enforcement release published Monday cited the firm for 12,391 apparent violations of OFAC sanctions regarding Iran, Syria, Cuba, and the Crimea region of Ukraine.
Between November 2017 and July 2022, daVinci enabled reward cards to be redeemed from persons apparently residing in the sanctioned jurisdictions, according to OFAC. The lapses were the result of flawed geolocation controls, the agency said.
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It has been nearly six months now since the Department of Justice’s (DOJ) Criminal Division released its memorandum on the selection of compliance monitors. This article provides a critical analysis of the monitorships that received early terminations, those that remain in place, and the broader compliance lessons they impart.
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