daVinci Payments

In November 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with daVinci Payments, which manages prepaid reward card programs. DaVinci Payments agreed to pay $206,213 to resolve potential civil liability for apparent violations of U.S. sanctions on Crimea, Iran, Syria, and Cuba. Between November 2017 and July 2022, daVinci enabled reward cards to be redeemed by persons in these sanctioned jurisdictions.

The violations included over 12,000 transactions where prepaid cards were used by individuals with IP addresses or email domains associated with the sanctioned countries. The majority of these violations were discovered during an internal compliance review conducted by daVinci between 2020 and 2022. Despite the violations, OFAC determined that daVinci's actions were non-egregious and had been voluntarily self-disclosed. Additionally, daVinci took significant remedial measures to address the compliance issues, including implementing protocols to block IP addresses and email domains from the sanctioned regions.