International Business

Please summarized and turn it into a slideshow.

•BLUF: (Bottom Line Up Front)
•Facts of the case/reference legal authority
•Issue
•Rule (what law was broken)
•Analysis

Case: https://www.oyez.org/cases/2011/10-1491

Attached an example on how the slideshow should look like 

KRAKEN EXCHANGE
LAWSUIT

Trevor, Woojin & Marbel

TABLE OF
CONTENT

01.

02.

BOTTOM LINE UP FRONT

FACTS OF THE CASE / LEGAL AUTHORITY

What’s the case about?

03.

ISSUE

04. RULE

What exactly happened – which legal authority?

What law has been broken?

BLUF

05.

ANALYSIS

Outcome of the case

TERMINOLOGY01.

02.

OFAC – OFFICE OF FOREIGN
ASSETS COUNCIL

AGGREVATING VS MITIGATING FACTOR

Financial intelligence and enforcement agency of the US Treasury Department. It
administers and enforces economic and trade sanctions in support of US national
security and foreign policy objectives

03. IP BLOCKING

04. GEOLOCATON

Any facts that increase the level of severity of any criminal activity.
Any fact or circumstance that lesses the severity or culpability of a criminal
act

05. BLOCKCHAIN
Distributed database that maintains a continuously growing list of ordered
records, called blocks

Process of identifying the geographical location of a person or device by
means of digital information processed by the internet

Configuration of a network service that blocks request from hosts with
certain IP addresses.

BOTTOM LINE

San Francisco based Virtual
Crypto Currency Exchange
company

daily trading volume is
around $333 million
9 million users worldwide
(2023)

Sued by OFAC – breaching its
regulations regarding trading
with citizens from Iran which is
forbidden.

FACTS &
ISSUE

Kraken Case

01.

FACTS

ISSUE

Maintained anti-laundering and
sanctions compliance program.
IP address information @
onboarding
826 transactions from Iran –> $
1,680,577
OFAC – Office of Foreign Assets
Control

Kraken engaged in 826
apparent violations of

the Iranian Transaction
and Sanctions

Regulations
$ 1,680,577 from Iran

“IRANIAN TRANSACTIONS AND
SANCTIONS REGULATIONS

31 C.F.R. §560.204

31 CFR § 560.204

826 violations of the Iranian
Transactions and Sanctions
Regulations
560.204 prohibits unauthorized
export and re-export, sale or
supply, directly or indirectly from
the United States or by an US
person, wherever located, of any
goods, technology or services to
Iran or the Government of Iran.

SETTLEMENT OF
$362,158.70

MAXIMUM CIVIL MONETARY PENALTY APPLICABLE IN THIS MATTER IS
$272,228,96.

ACCORDINGLY, UNDER OFAC’S ECONOMIC SANCTIONS ENFORCEMENT
GUIDELINES THE BASE CIVIL MONETARY PENALTY
APPLICABLE THE SUM OF ONE-HALF OF THE TRANSACTION VALUE FOR EACH
APPARENT VIOLATION, WHICH IS $840,288.55.

ANALYSIS

Aggravating Factors
Kraken failed to exercise due caution or care for its sanctions compliance
obligations when, knowing it had customers worldwide, it applied its
geolocation controls only at the time of onboarding and not with respect to
subsequent transactional activity, despite having reason to know based on
available IP address information that transactions appear to have been
conducted from Iran.

Mitigating Factors
voluntarily self-disclosed and cooperated with OFAC
never received a penalty in 5 years.
undertook significant measures
sanctions compliance program

BIBLIOGRAPHY

https://en.wikipedia.org/wiki/Office_of_Foreign_Assets_Control

https://www.investopedia.com/tech/what-
kraken/#:~:text=Kraken%20is%20a%20cryptocurrency%20exchange,euros%2C%20and

%20the%20Japanese%20yen.

https://www.usesignhouse.com/blog/kraken-stats
(PDF Provided)