CoinBase, Circle, and Bittrex leaving USA and heading to the MENA region

CoinBase, Circle, and Bittrex leaving USA and heading to the MENA region

The exodus of Crypto and Blockchain startups from the United States seems to be intensifying and it looks like the MENA region, and UAE are the new preferred destinations for CoinBase, Circle and Bittrex. 

Tim Draper, Founder of DFJ VC tweeted recently that Silicon Valley startups are relocating to Middle East, Asia, and Europe.

He states, “CoinBase and Gemini are moving out of the US for regulatory reasons. Dubai, London and Singapore are eating into New York’s blockchain leadership. This exodus is not good for US jobs, economy, and homelessness.”

Additionally, in the last 24 hours CoinBase announced that its CEO and Co-Founder Brian Armstrong is currently in the UAE for a series of engagements with policymakers, regulators, partners, Web3 and crypto founders as well as clients.

Armstrong is delivering a keynote address at the inaugural Dubai Fintech Summit, under the patronage of His Royal Highness, Sheikh Maktoum bin Mohammed bin Rashid Al Maktoum, First Deputy Ruler of Dubai, Deputy Prime Minister and Minister of Finance.

As per CoinBase blog, “Crypto and Web3 serve as enormous opportunities for economic and technological diversification for the UAE, and the region has the potential to be a strategic hub for CoinBase, amplifying our efforts across the world.”

The blog adds, “It further serves as a particularly strategic bridge between Asia and Europe – two of our existing focus international regions to date.”

CoinBase reiterated that it is not only working with Abu Dhabi Global Market (ADGM) regulators to further expand the licensing and availability for CoinBase International Exchange but is also engaging with Dubai’s Virtual Assets Regulatory Authority (VARA), a dedicated regulator for virtual assets, as they put forward a comprehensive retail framework built on the principles of economic sustainability and cross-border financial security. 

CoinBase believes that their presence in the UAE will not only expand their global footprint but also help to bring 1 billion users to crypto.  

The blog adds that the MENA region is out to be a leader in the development of a web3 ecosystem, making it an attractive location to consider investing in. The vacuum created by other notable jurisdictions means that international counterparts, such as the UAE, are racing to fill the regulatory gap.

CoinBase is not the only US Company that is looking at the UAE. It also seems Circle is interested in the region as well. The Circle team were recently present in Dubai UAE at a dinner hosted by Miriam Kiwan, the partner of Raiven Capital.

Jeremy Allaire, CEO of Circle Internet Financial, during an interview with Bloomberg, blamed the shrunken value of the company’s stablecoin, USD Coin, on regulatory challenges in the United States and concerns about its banking system.

In addition in March 2023 the SEC sued crypto exchange Bittrex shortly after it announced it was leaving the US markets. Bittrex, announced it would no longer do business with U.S. citizens because “it’s just not economically viable for us to continue to operate in the current U.S. regulatory and economic environment.”

Stephen Stonberg, CEO of Bittrex Global crypto exchange  has stated that the UAE and Dubai are among the friendliest jurisdictions for the cryptocurrency industry. He added in a Bloomberg interview Dubai is likely to benefit from the expanding crypto market in the Middle East as local regulators increasingly accept blockchain related technologies.

Finally in a recent LinkedIn post by Ali Jamal, CEO of UAE based Cryptos Consultancy, a crypto and Blockchain licensing firm, he noted, “We at Cryptos Consultancy have been getting lots of queries from crypto and tradfi businesses about setting up Virtual Asset practices in Dubai. There is a real buzz around Dubai’s virtual assets ecosystem now that the Virtual Assets Regulatory Authority (VARA) regulations are out.”

So as crypto and Blockchain businesses flee the USA, the tightening regulations in the USA continue with The New York State Attorney General (NYAG) Office announcing last week that Attorney General Letitia James has proposed “landmark legislation to tighten regulations on the cryptocurrency industry to protect investors, consumers, and the broader economy.” The announcement stated, ” Attorney General James’ program bill, which proposes the strongest and most comprehensive set of regulations on cryptocurrency in the nation, would increase transparency, eliminate conflicts of interest, and impose commonsense measures to protect investors, consistent with regulations imposed on other financial services.” 

It seems that this is only the beginning and the MENA region with UAE and Bahrain at the helm will become the new crypto Silicon Valley. 

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UAE Based Blockchain entity Web3Wed carries out first wedding on the Blockchain

UAE Based Blockchain entity Web3Wed carries out first wedding on the Blockchain

UAE Based Web3Wed has carried out the first wedding on the Polygon Blockchain with NFT rings that incorporate Bitcoin. According to the press release, Web3Wed allows couples to formalize their relationships using smart contracts on the blockchain which is then updated in case of divorce.

The Blockchain marriage is not considered legal obligation though.

The first blockchain wedding marked the official launch of the Web3Wed.io platform. “The world is changing so fast, but marriages are still the same as centuries ago,” said Yury Reut, the founder, and CEO of Web3Wed.io. “Why can’t we connect people using blockchain? Co-living defeated the old matrimony system; it is a fact.”

Couples choose NFT wedding rings that symbolize their participation in the marriage. Additionally, the service can add Bitcoin to the NFT wedding ring, making it an asset for the couple that would be returned in the case of divorce to the wallet of the ring owner.

“We’re excited to offer an innovative solution to couples who are looking for a new way to formalize their relationship,” said Reut. “Our platform offers a decentralized, secure, and transparent way to record and manage marriages, making it the ideal solution for modern couples.”

The first-ever NFT engagement rings collection by Web3Wed.io will be available in June. Couples can purchase NFT wedding rings and initiate their blockchain marriage with them, while NFT engagement rings will allow them to make a beautiful proposal.

The Blockchain marriage service, Web3Wed.io, hosted the first blockchain wedding on April 28, 2023, at Bali’s K-Club, Ubud. Ilya and Elizabeth tied the knot and recorded their union in a smart contract on the Polygon blockchain.

Could this be the future of all marriage arrangements without the hassle of lawyers. 

Crypto Exchange RAIN Bahrain traded $484 million worth of crypto with Ethereum and XRP leading over Bitcoin

Crypto Exchange RAIN Bahrain traded $484 million worth of crypto with Ethereum and XRP leading over Bitcoin

Crypto Broker Exchange RAIN Bahrain has traded $484 million worth of crypto since its inception in 2019 with Ethereum the most traded crypto asset followed by XRP. 

RAIN has noted that it has a  customer base of 75,000 from Bahraini residents signed up on the platform. 

According to the RAIN LinkedIn post “We’re thrilled to share some exciting news about our impact on the Kingdom’s crypto market! Since launching Rain in 2019, we’ve been able to offer our customers a reliable and secure platform for trading crypto assets. We’re grateful for Bahrain’s strong support for innovation and entrepreneurship, which has contributed to our success. Thank you to the people of Bahrain and Team Bahrain for your unwavering support!” 

As per their statistics 41% of active crypto traders in Bahrain chose RAIN, while 5% of crypto trades in Bahrain are carried out on RAIN. 

In addition the biggest traded cryptocurrencies on RAIN Bahrain are Ethereum, Bitcoin, XRP, Litecoin and tether. Statistically Ethereum has the highest percentage of trades at 37% followed by XRP (Ripple token) at 25% and Bitcoin at 20%, while Litecoin 7% while Tether USDT is 5% of trade and 6% is distributed to others. 

In terms of the age groups trading on RAIN, the biggest age group is from 30-34 years old followed by those over 40 years old. The youth make up only 10% and refers to those from18 to 24 years old, while 22% are from 25 to 29 year olds. 

Bahrain was the first country in the GCC to launch crypto exchange licenses and RAIN was the first operator to launch in Bahrain. Since then CoinMENA, Binance have followed suite. In addition recently BitOasis also noted that it was in the midst of receiving a license in Bahrain. 

Bahrain also recently was the first country in the GCC to issue onshore security token regulations.

Blockchain crypto veteren James Bernard appointed as Chief Commercial Officer at UAE’s RAK Digital Assets Oasis

Blockchain crypto veteren James Bernard appointed as Chief Commercial Officer at UAE’s RAK Digital Assets Oasis

UAE’s latest digital asset and Web3 free zone in Ras Al Khaimah, RAK DAO, has appointed James Bernard at its Chief Commercial Officer. Bernard has been working in the digital asset blockchain sector since 2015. In the UAE he worked within Dubai’s DMCC and later on as an advisor to several Web3 blockchain entities within the UAE.

James will be responsible for all commercial activities, the implementation of business strategies and the development of partnerships, supporting entrepreneurs, innovators, and businesses across new and emerging tech sectors, digital assets, and web3, metaverse, AI, NFT, DApp, AI, blockchain, tokenization as well as many others. 

He was a founding member in 2015 of the Global Blockchain Council in Dubai, and leading DMCC’s Crypto strategy, developing early proof of concepts for various Web 3.0-powered ventures including Diamond Track and Trace, and property leasing applications, while also launching crypto asset licenses and making significant contributions to regional regulatory environment.

Commenting on James’ appointment, Dr. Sameer Al Ansari, CEO of RAK Digital Assets Oasis, said: “James brings with him a wealth of experience across the web3, digital assets and future tech landscape, enabling us to develop truly ground-breaking, strategically positioned models to support these sectors and tap into the growing global tech-enabled markets. We aim to open our doors to the companies of the future in the second quarter of 2023 and at such a crucial point in our emergence as innovation-enablers, we have no doubt that James’ formidable knowledge and experience will help us reach our ambitious targets.”

James Bernard, CCO of RAK Digital Assets Oasis, said: “I am thrilled to be part of RAK Digital Assets Oasis. With our forward-leaning approach to maximizing opportunities in disruptive technologies, the free zone is committed to supporting, empowering, and partnering with global leaders, entrepreneurial talent and innovators, building transformative solutions and creating impact.”

MENA open banking platform Tarabut gateway raises $32 million to expand in KSA

MENA open banking platform Tarabut gateway raises $32 million to expand in KSA

MENA based Tarabut open banking platform, which recently signed its first partnership with a crypto brokerage exchange RAIN in Bahrain, has raised $32 million in its series A, led by Pinnacle Capital. The funds will be used to bolster Tarabut’s footprint in Saudi Arabia.

Pinnacle Capital is a leading alternative investment firm that focuses on KSA investments to provide unique alternative investment opportunities. Pinnacle Capital partners have extensive transactional experience in the venture capital industry with a proven track record, including leading the first Saudi unicorn tech startup, Jahez, to a public listing. The raise also saw participation from Aljazira Capital, Visa, Tiger Global, and other leading existing investors.

Abdulla Almoayed, Founder and CEO of Tarabut Gateway, stated, “Open banking is reshaping the financial landscape in KSA and the wider Middle East, and we, at Tarabut Gateway, are proud to be at the forefront of this innovation. This fundraise reflects the potential of open banking, our advanced technology, and the trust placed in us by our partners both in KSA and globally. Tarabut Gateway’s mission is to create an open financial services sector that delivers open banking benefits to MENA’s consumers, banks, and fintechs – and the proceeds of this fundraise will help us execute our strategy and contribute to realizing the Kingdom of Saudi Arabia’s ambitious vision 2030.”

In KSA, Tarabut Gateway has achieved over 60% market coverage through partnerships with leading banks such as Alinma Bank, Arab National Bank, Saudi National Bank and Riyad Bank. The Saudi Central Bank (SAMA) has included Tarabut Gateway as one of the first participants in its Regulatory Sandbox, which is a key component of the open banking framework rollout.

Tarabut Gateway will also be partnering with Visa. Andrew Torre, Regional President of Visa CEMEA, said, “Next-generation digital experiences and innovation are driving the future of financial services, and open banking is a growing movement that can help consumers better access and manage finances. We look forward to partnering with Tarabut Gateway, combining our global payments network and proven local solutions with their open banking platform to allow innovative financial services across the region.”

Abdulwahab Al Betairi, Founding Partner of Pinnacle Capital, added, “We’re thrilled to be backing Tarabut Gateway’s ambitious growth plans. Their innovative approach to open banking and their strong focus on Saudi Arabia make them a perfect partner for us, and we’re excited to see them grow to new heights and contribute to the growth of the Saudi Arabian fintech space as part of the Vision 2030 strategy.” 

Prior to this announcement, Tarabut Gateway partnered with Rain. As per the announcement it would brig faster, cost effective fiat to crypto transaction to Bahrain end users and enable funding payments directly from user bank accounts without leaving Rain’s platform.

The new feature will utilize Tarabut Gateway’s open banking payment solutions to facilitate on and off-ramp (fiat-crypto-fiat) transfers for users, dramatically increasing speed and reducing errors associated with traditional bank wire transfers.

Abdulla Almoayed, Founder and CEO of Tarabut Gateway, stated at the time that crypto trading, crypto wallets and other blockchain use cases were a natural ally in opening up traditional banking and finance. He stated, “We’re delighted to unveil a solution that aims to make fiat-to-crypto transfers quicker, more secure, and cost-effective – as well as enable such funding methods directly from bank accounts. We are proud to partner with Rain to provide a user-focused approach to crypto services by bringing the advantages of open banking digital solutions.”

A 10th bank in UAE joins Blockchain KYC platform under Dubai’s Department of economy and tourism

A 10th bank in UAE joins Blockchain KYC platform under Dubai’s Department of economy and tourism

Al Masraf bank has become the 10th bank to join the Norbloc KYC Blockchain platform developed under the initiative with Department of Economy and Tourism (DET).

Al Masraf has announced the launch of a project that will see it connecting to the norbloc Fides platform, a blockchain-based solution that allows for the secure sharing of eKYC data. The network, which has been live since 2020, connects licensing authorities, free zones and financial institutions across the emirates in an ecosystem, where a single version of each customer KYC file is maintained and shared, ensuring that financial institutions always have access to the latest and most up-to-date KYC data.

Graham FitzGerald, CEO Al Masraf stated, “Becoming part of the Fides ecosystem allows us to obtain all of these objectives, as well as join other leading financial institutions in making use of this innovative technology. It is an important step with in line with a broader effort to digitize and streamline our customer journeys.”

Astyanax Kanakakis, CEO and Co-Founder of nobrloc  added, “Al Masraf is an important addition to the Fides platform which greatly benefits from the networking effects of having more institutions connect to it. There are currently 15 entities participating in the ecosystem, making it one of the most advanced eKYC utilities globally. Al Masraf is also the first institution to make use of our recently announced SaaS connectivity option, meaning that they will be able to start consuming KYC data in a matter of weeks.”

Al Masraf becomes the 10th bank to join the network which also includes Mashreq Bank, ENBD, HSBC, ADCB. Licensing authorities and free zones such as DIFC and Ras Al Khaimah Economic Zone participate acting as data providers on the network.

In April 2023, the first Islamic Bank joined The KYC platform as well. 

The project was launched in February 2020. In 2021, the Blockchain KYC Fides Platform built by Norbloc for both Dubai Economy and DIFC became one platform for the entire UAE. Dubai Economy and Dubai International Financial Centre (DIFC) Authority agreed to consolidate efforts and expand the UAE KYC (Know Your Customer) Blockchain Consortium positioning it as the national corporate e-KYC Platform, making it the first such platform in the region.

UAE Helion Ventures is going to Lebanon with Beirut Digital District

UAE Helion Ventures is going to Lebanon with Beirut Digital District

UAE Helion Ventures investment, is heading to Beirut Lebanon for a round table meeting on May 11th at Beirut Digital District. Helion launched its operations in Dubai’s DIFC in September 2022 focusing on four major sectors, banking 3.0, healthcare, tokenization of real world assets, green technology, gaming, and fintech in projects across the GCC and African region.

The founders, Oliver von Wolff and Bojan al Pinto Brkic, have long-term experience in venture capital and regulated products. Oliver von Wolff, Founder and CEO, at launch stated, “Our products and services perfectly complement the ecosystem for Dubai start-ups, we are a classic equity provider and venture builder with focus on institutional investors”, to which Bojan added “we intend to capitalize on our experience, bringing the investment management know-how to new industries, such are blockchain and fintech, and even gaming and crypto.”

It is not surprising to see Helion Ventures off to Beirut, given that they are one of the most active investment venture entities when it comes to partnerships and event participation. Just before Beirut, launched Helion has partnered with Crypto 306 event taking place on May 8th 2023 at the Ritz Carlton in Dubai UAE.

Partnerships are a key pillar for Helion. For example, They have partnered with Syndicate Capital Group incubator given Helion’ interest in investing in South East Asia. Earlier, they partnered with the African Chamber of Digital Commerce, and the Hong Kong Federation of e-commerce.

Their spirit of partnerships goes even further, as they have equally partnered with other venture builders such as UAE based Masary Capital, New Tribe Capital, and Uganda based CryptoSavannah.

When it comes to startups, their most well-known investments and partnerships include cryptobank, DeFi startup Yieldster, dOTC MarsBase, DeFi OTC desk as well as African Blockchain internet startup 3air.

The 3air ecosystem is built to make it easier for previously unconnected users to join the global blockchain community. Internet subscriptions are purchased which grant the user a Connectivity NFT that can be shared, transferred and used at any 3air-compatible location. Once connected, 3air’s blockchain platform offers users access to the world of blockchain and DeFi. Users can own a digital identity, create wallets, take micro-loans and participate in revenue-generating activities.

Helion has even partnered with UAE free zones such as IFZA International Free Zone Authority

LaraontheBlock spoke to Oliver earlier to understand why Helion Ventures chose to set up in UAE and focus on MENA and Africa. He stated, “Given my previous role at Swiss Based CV Labs and then at Dubai’s Crypto Oasis, I helped build UAE’s Web3 ecosystem. So when I ventured to launch Helion I thought of Dubai because it has three essential pillars, financial capital, infrastructure, and human capital as well as its entrepreneurial spirit.”

He adds, “Helion Venture stands in the middle on one side we have friends and family investors which is not regulated and on the other we offer family offices and high network individuals the opportunity to invest with us.”

Helion invests anywhere between $50,000 – $100,000 for early pre seed stage projects, and take equity stakes for anywhere between $250,000- $500,000. They invest both in tokens and equity.

According to Oliver, Helion has a steady good quality deal flow given his long term experience and his former work at CV Labs and as such there are always great projects being presented to Helion and not spam projects.

He explains, “ We carry out strong due diligence and make selected investments, but we are also venture builders which means we actively manage our investments by supporting them with marketing, networking, business cases and so forth. We are also always open to working with other VCs because we believe if one VC has a strong project it should be shared to support these projects even more.”

While Helion’s policy is not to lead investments they do like to be anchor investors. Oliver clarified, “Anchor investors give money and support while lead investors like to take a more strategic managerial influence which I believe is not the best choice. When we invest we have already done our due diligence and trust the technology but more importantly the team.”

Oliver is bullish for2023 and believes crypto markets will go up in mid-2023. He sees the biggest markets will come from NFTs that actually have customer uses cases, like ticketing, etc.. and also sees the metaverse growing with serious projects as well as early stage token market.

Blockchain Integration Cloud platform launched in MENA region

Blockchain Integration Cloud platform launched in MENA region

Blockchain compatible EVM ( Ethereum Virtual Machine) platform built on NEAR protocol, Aurora Labs, with offices in Business Bay in Duba, has launched its Aurora Cloud in the MENA region.

The platform is designed to integrate blockchain technology to their business without friction or the need for expert teams, significant resources, or large investments in time. With Aurora Cloud, businesses can connect their existing products to their own blockchain, allowing for a seamless end user experience that still looks familiar to what their customers use every day.

The platform enables businesses to choose to operate on their own private blockchain, known as an Aurora Silo, implementing KYC/KYB access restrictions and dictating which apps and tokens are available to trade and use, allowing for a bespoke and tailored experience. The ability to control whether they or their customers are responsible for gas fees is another game-changing feature that provides total commercial flexibility and a strong incentive to both businesses and their consumers.

Whilst Aurora Cloud is largely an industry agnostic solution that can provide blockchain benefits across a wide range of industries, the company sees significant benefits for Fintech companies, brokers, banks, investment funds, the energy sector, and those operating within the luxury goods and retail spaces.

“The launch of Aurora Cloud is an exciting moment for Aurora Labs and the wider blockchain industry. With our unique products and innovative approach, we are breaking down the technical barriers and increasing the transition of traditional businesses to the blockchain,” said Alex Shevchenko the CEO of Aurora Labs. “We are confident that Aurora Cloud will position us at the forefront of this shift and provide the industry with a much wider pool of potential customers and partners.”

Aurora raised $12 million in October of 2021. 

UAE based WadzPay chosen as finalist at Currency Research Awards for its Blockchain enabled Saudi Hajj Payment solution

UAE based WadzPay chosen as finalist at Currency Research Awards for its Blockchain enabled Saudi Hajj Payment solution

UAE based WadzPay Blockchain enabled Hajj Pilgrim Digital payments solution has been chosen as a finalist at Currency Research’s second annual Advancement in Digital Currency Awards, being presented at the Digital Currency Conference in Mexico City, on May 18th, 2023. WadzPay’s solution was chosen under the category for Best Innovation in Digital Currency. WadzPay is competing against top international blockchain fintech providers such as Stellar.

According to Parv Aggarwal, Vice President for CBDCs and Partnerships, “We are super excited to represent WadzPay and our novel cross border Hajj Pilgrimage token.”

Currency Research awards are presented to digital currency initiatives that advance the platform as a payment instrument. Currency Research chooses entities who are working on all types of digital currencies at all stages of developments.

The award categories include “Outstanding Advancement in Digital Currency” whose category finalist for this year include, Crunchfish,  eCurrency,  and FNA.

The second award category is “Best Innovation in Digital Currency” which recognizes outstanding innovations in the digital currency space, including new platforms, products, or apps that have the potential to transform the way we use and interact with digital currencies, including central bank digital currencies (CBDCs).

The category is open to innovations that have launched and have customers, and that offer users a unique and valuable way to access digital assets, crypto, DeFi, or other related financial      services, including CBDCs. Innovations that offer greater security, transparency, and scalability in the digital currency space, or that leverage emerging technologies such as AI, will be given special consideration. The judges will consider factors such as the level of innovation, the potential impact on the industry, and the ability of the innovation to scale and reach a wider audience.

WadzPay, Currency Network, and Stellar will be competing as finalists for this category.

Other award categories include Best Financial Inclusion Initiative in Digital Currency. This award recognizes initiatives that have been developed to promote financial inclusion in the digital currency space. This category is open to projects that have demonstrated success in providing access to digital currency and related financial services to traditionally underserved or unbanked populations. This includes initiatives that aim to reduce barriers to entry for low-income individuals, women, and other marginalized communities. 

Jordanian headquartered Fintech solution provider ProgressSoft will be competing against eCurrency, and IDEMIA.

The Best Sustainability Initiative in Digital Currency category will see competition between Andrei Lipkin, Ripple and Stellar

As for the final award category” Digital Currency Leader of the Year” which recognizes outstanding individual who has consistently contributed to the advancement of the digital currency sector, finalists includes Jonathan Dharmapalan, eCurrency, James Wallis from Ripple, and Shiva Bissessar from Pinaka Consulting Ltd.

Poloniex crypto exchange pays $7.5 million settlement to OFAC for dealing with customers in Syria, Sudan, Iran, Crimea

Poloniex crypto exchange pays $7.5 million settlement to OFAC for dealing with customers in Syria, Sudan, Iran, Crimea

US based Poloniex, LLC, a Delaware company with its principal place of business in Boston, Massachusetts which previously operated an online trading and settlement platform previously doing business as Poloniex Inc. (hereinafter collectively “Poloniex”) has agreed to remit $7,591,630 to settle its potential civil liability for 65,942 apparent violations of multiple sanctions programs with countries such as Syria, Sudan, Iran, and Crimea with U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC.)

 As noted by OFAC, between January 2014 and November 2019, the Poloniex trading platform allowed customers apparently located in sanctioned jurisdictions to engage in online digital asset-related transactions consisting of trades, deposits, and withdrawals—with a combined value of $15,335,349, despite having reason to know their location based on both Know Your Customer information and internet protocol address data.

As per the OFAC statement, the settlement amount reflects OFAC’s determination that Poloniex’s apparent violations were not voluntarily self-disclosed and were not egregious.

The statement went on to read, “Although Poloniex made efforts to identify and restrict accounts with a nexus to Iran, Cuba, Sudan, Crimea, and Syria pursuant to its compliance program, certain customers apparently located in these jurisdictions continued to use Poloniex’s platform to engage in online digital asset-related transactions.”

Poloniex operations began in January 2014 by offering an online digital assets trading and settlement platform (“Poloniex Trading Platform”) that allowed customers to fund their accounts and conduct trading activity. Sixteen months later, in May 2015, Poloniex implemented a sanctions compliance program, which provided for a review of KYC information for new customers in jurisdictions subject to comprehensive OFAC sanctions; existing customers were not retroactively screened in this manner.

As a result, customers who had self-identified before May 2015 as residing in a sanctioned jurisdiction (i.e., customers who provided an address located within a sanctioned jurisdiction to Poloniex during the KYC process at the time of account opening) were generally able to continue using Poloniex’s platform. . Poloniex did not begin implementing a block on such IP addresses until June 2017. Poloniex implemented sanctions controls related to customers in the Crimea region of Ukraine only in August 2017.

 Although Poloniex made efforts to identify and restrict accounts with a nexus to Iran, Cuba, Sudan, Crimea, and Syria pursuant to its compliance program, certain customers apparently located in these jurisdictions continued to use Poloniex’s platform to engage in online digital asset-related transactions (the “Apparent Violations”).

Stablecoin issuer Circle acquired Poloniex in 2018, after which time, OFAC’s investigation concluded, the firm’s compliance measures “further improved,” specifically by closing accounts with IP addresses operating in Crimea. A group of investors, which included Tron founder Justin Sun, purchased the firm from Circle in 2019.