FCC Flash

On November 6, 2023, the Office of Foreign Assets Control (OFAC) penalized DaVinci Payments for violations of Multiple Sanctions Programs.

To read more, click here https://www.fcctimes.com/2023/11/06/davinci-payments-settles-with-ofac-206213-fine-for-alleged-sanctions-violations-in-crimea-iran-syria-and-cuba/?utm_source=RZOLUTWebsite&utm_medium=FCCFlash24Nov

From November 15, 2017, to July 27, 2022, DaVinci, a prepaid reward card program management company, permitted the redemption of reward cards from individuals residing in sanctioned jurisdictions. DaVinci has agreed to pay $206,213 to settle its potential civil liability for 12,391 alleged violations of OFAC sanctions.

OFAC determined the following violations:

  • Enabled redemption of reward cards from individuals residing in sanctioned countries such as Iran, Syria, Cuba, and Crimea.
  • On 12,378 occasions, prepaid cards with IP addresses linked to sanctioned countries were redeemed, amounting to USD 549,134.
  • Failed to implement a compliance program/controls regarding the knowledge of users’ IP addresses and fake email address suffixes.

OFAC identified the following as mitigating factors:

  • Companies should verify a customer’s identity and location using location-related data such as IP addresses and top-level domains, or other geolocation tools, whenever feasible.
  • Conduct real-time screening and blocking of email address suffixes and institute independent third-party testing at regular intervals.
  • Online firms should incorporate customer information into a risk-based sanctions compliance program to prevent services from being provided to individuals in sanctioned jurisdictions.