Kraken had an AML program, including a sanctions compliance program, including screening on onboarding and daily screening of its customers.
The company also reviewed IP address information on onboarding to prevent the onboarding of users from sanctioned jurisdictions.
However, between October 2015 and June 2019, Kraken:
- Processed 826 transactions
- Totalling $1,680,577.10
- on behalf of individuals who appeared to be located in Iran at the time of the transaction.
Failure:
Kraken checked the IP address on customer onboarding but not on the transactional activity of its clients.
