Office of Foreign Assets Control (OFAC)for its abbreviation in English) of the United States Government It reached an agreement with DaVinci Financial to pay a fine of $206,213 On charges of “violating multiple sanctions programs” by Washington against the Cuban regime and three other countries.
DaVinci Payments, a payments and financial services company headquartered in Buffalo Grove, Illinois, It agreed to pay the amount to resolve its potential civil liability for 12,391 apparent violations of OFAC sanctions To Cuba, Crimea, Iran and Syria, areas where financial transactions from the United States are controlled.
Good With the Cuban-American Economic and Trade Council, the federal entity’s decision noted that between November 15, 2017 and July 27, 2022, the company, which operates prepaid rewards card programs, allowed them to be redeemed by persons who appeared to be residents of jurisdictions that imposed Washington.
Despite the penalty, according to the council’s analysis. “The settlement amount reflects OFAC’s determination that DaVinci’s conduct was not egregious and was voluntarily disclosed.”
According to the ruling, DaVinci offers digital or physical payment rewards card programs through an online platform to corporate, nonprofit and government clients, allowing its customers to issue payment cards to specific recipients, typically as part of a loyalty, reward or promotion incentive for employees, customers and other recipients.
This way, daVinci customers finance the card programs through their issuing bank, while the company provides the prepaid digital or physical cards. But users cannot enter an address in a US-sanctioned jurisdiction.
However, between March 2020 and February 2022, during a compliance review and subsequent investigation, DaVinci discovered that On 12,378 occasions, it replaced prepaid cards for users with addresses linked to Cuba, Iran, Syria and Crimea.
After Da Vinci began blocking access to its platform from IP addresses associated with these jurisdictions, The company also discovered that it had recovered prepaid cards for 13 recipients who used email addresses with domains associated with sanctioned countries. During the exchange or who was apparently staying there.
The total amount recovered by DaVinci in this period was $549,134.89.
In its ruling, OFAC determined that the aggravating factor was that DaVinci did not exercise due diligence when redeeming the cards, but it took into account several mitigating factors, including that the company “took a series of significant corrective actions, including conducting an internal review.” Proactively implement IP address blocking from sanctioned jurisdictions, conduct real-time review, and block email address suffixes.”
“This case also illustrates potential deficiencies in controls based on customer-provided informationOFAC noted that “rather than a comprehensive information collection system could mitigate evasion or misrepresentation.”
DaVinci Payments, for its part, “identified and notified the banking partners of the activity and took immediate action to stop the activity,” the company said in an emailed statement to US media. Compliance News.
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