Uphold HQ Inc. (Uphold)

Uphold HQ Inc., a California-based money services business, has agreed to pay $72,230.32 to settle its potential civil liability for 152 apparent violations of U.S. sanctions against Iran, Cuba, and Venezuela between March 2017 and May 2022. The violations included processing transactions for customers who self-identified as being located in Iran or Cuba and for employees of the Venezuelan government. Uphold failed to screen customer-provided free-text address fields and identification documents, allowing users from sanctioned jurisdictions to access financial services. The company processed 53 transactions totaling $22,870.02 for Iran, 25 transactions totaling $142,683.74 for Cuba, and 58 transactions totaling $1,316.54 for employees of Venezuela’s state-owned oil company, PdVSA. OFAC determined the violations were non-egregious and voluntarily self-disclosed, significantly reducing the statutory maximum penalty of $44.4 million to the final settlement amount.