Recent OFAC Settlement Highlights Need to Consider IP Address Geolocation Data
By EsqSocial Corporation 13/01/21
On December 30, 2020, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with BitGo, Inc. (“BitGo”) for providing digital wallet services to users located in sanctioned jurisdictions, including Crimea, Cuba, Iran, Sudan, and Syria. The case is notable because OFAC makes clear its expectation that companies consider Internet Protocol (“IP”) address geolocation data when assessing whether online customers are located in sanctioned jurisdictions....
By: Kelley Drye & Warren LLP