Platform operations secured amid sanctioned-party access allegations
Situation:
A global cryptocurrency exchange faced a threatened OFAC designation based on allegations that sanctioned parties had accessed the platform. The threat created immediate operational and reputational risk, with the potential for platform-wide disruption if OFAC proceeded with the designation.
Stakes:
A designation could have frozen the exchange’s assets, severed banking relationships, and triggered compliance obligations for counterparties and service providers worldwide. The platform faced potential shutdown, market disruption, and reputational harm extending far beyond the underlying allegations. Immediate, coordinated engagement with OFAC’s Office of Global Targeting was required.
Result:
Ferrari & Associates served as U.S. OFAC counsel throughout the pre-designation defense, coordinating a request for stay of designation, overseeing an independent internal investigation, preparing detailed responses to OFAC information requests, and managing direct engagement with the Office of Global Targeting.
The firm also evaluated a voluntary self-disclosure to OFAC Enforcement and advised on remediation, including freezing accounts associated with sanctioned persons. The coordinated defense and transparent agency engagement prevented the threatened designation, allowing the platform to continue operating while demonstrating disciplined compliance controls and a cooperative posture.
