On December 9, FinCEN announced a consent order levying a $3.5 million civil money penalty against a peer-to-peer virtual currency trading platform for willful BSA violations. FinCEN alleged the company facilitated more than $500 million in suspicious transactions involving illicit actors and high-risk jurisdictions, including individuals from Iran, North Korea, and Venezuela.

FinCEN found that the company failed to register as a money services business, did not develop or maintain an effective anti-money laundering program, and did not file the required suspicious activity reports. The company admitted that these violations were willful. The order stated that the company’s deficiencies allowed illicit actors to use the platform for transactions linked to ransomware, darknet markets, child exploitation, terrorist financing, and sanctioned countries. In determining the penalty, FinCEN considered mitigating factors, including the company’s subsequent termination of prior leadership, remediation efforts, and a review to identify and report previously unreported suspicious activity.