New OFAC Guide Addresses Risk-Based Approaches to Sanctions, Payment Tech

WASHINGTON—A new guide from the Treasury Department is emphasizing the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems, and to highlight considerations relevant to managing those risks.

The U.S. Department of the Treasury's Office of Foreign Assets Control, which published "Sanctions Compliance Guidance for Instant Payment Systems,” said the guidance also encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.

Separately, OFAC has also announced a settlement with Tango Card, Inc., a Seattle-based company that supplies and distributes electronic rewards.  Tango Card agreed to remit $116,048.60 to settle its potential civil liability for 27,720 apparent violations of multiple U.S. sanctions programs.  

Voluntarily Self-Disclosed

As a result of deficient geolocation identification processes, Tango Card transmitted stored value products to individuals with Internet Protocol (IP) and email addresses associated with Cuba, Iran, Syria, North Korea, and the Crimea region of Ukraine, OFAC said.  

The settlement amount reflects OFAC’s determination that Tango Card’s apparent violations were non-egregious and voluntarily self-disclosed.

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