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End of Quarter Clearance at OFAC: an enforcement action, a related guidance document… oh, and yes, Libyan sanctions regs

Sanctions Compliance Guidance for Instant Payment Systems; Settlement Agreement between OFAC and Tango Card, Inc.; Issuance of Libyan Sanctions Regulations

Release date



The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing “Sanctions Compliance Guidance for Instant Payment Systems” which emphasizes the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems and to highlight considerations relevant to managing those risks.  This guidance also encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.

In addition, OFAC announced a settlement with Tango Card, Inc. (Tango Card), a Seattle, Washington-based company that supplies and distributes electronic rewards.  Tango Card agreed to remit $116,048.60 to settle its potential civil liability for 27,720 apparent violations of multiple U.S. sanctions programs.  As a result of deficient geolocation identification processes, Tango Card transmitted stored value products to individuals with Internet Protocol (IP) and email addresses associated with Cuba, Iran, Syria, North Korea, and the Crimea region of Ukraine.  The settlement amount reflects OFAC’s determination that Tango Card’s apparent violations were non-egregious and voluntarily self-disclosed.  For more information, please visit the following web notice.

OFAC is also reissuing in their entirety the Libyan Sanctions Regulations, 31 CFR 570, which were previously published in abbreviated form in 2011. Today’s reissuance of the Libyan Sanctions Regulations includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public.

OFAC Recent Action of September 30, 2022

Mr. Watchlist’s Note: I will post the guidance doc and the enforcement action separately for easier reference.


OFAC Notice

Sanctions Compliance Guidance for Instant Payment Systems

Enforcement Action

Libyan Sanctions Regulations

Categories: Civil Monetary Penalties Cuba Sanctions Enforcement Actions Guidance Iranian Sanctions Libya Sanctions North Korea (DPRK) Sanctions OFAC Updates Syrian Sanctions Ukraine sanctions


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