Zulutrade, Inc. OFAC Settlement: $200K (2014)

Last updated: July 20, 2026

Zulutrade, Inc., a Delaware-incorporated entity registered with the Commodities Futures Trading Commission (CFTC), settled potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations, the Sudanese Sanctions Regulations, and Executive Order 13582, "Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria." Zulutrade agreed to pay $200,000 to resolve the matter.

Penalty Amount

$200,000.00

Enforcement Date

September 9, 2014

Rank in Top Penalties

#192

Case Details

Type:: Entity
Name:: Zulutrade, Inc.
Country:: 🇺🇸 United States
Industry:: Payments
Address:: Delaware
Penalty amount:: $200,000.00
Base civil monetary penalty:: $844,090,000.00
Egregious case:: No
Voluntary self disclosure:: No
Case:: Settlement
Violation period:: From 2009
Program:: Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560Sudanese Sanctions Regulations (SSR), 31 C.F.R. part 538Executive Order 13582 (E.O. 13582)
Enforcement date:: September 9, 2014

Nature of the Apparent Violations

Zulutrade operates an electronic trading platform that allows customers to automatically place currency foreign exchange (FX) trades with broker-dealers. Over a number of years beginning in 2009, Zulutrade maintained accounts for over 400 persons in Iran, Sudan, and Syria, and exported services to these customers by placing FX trades via its platform. Zulutrade also originated eight funds transfers totaling $10,264.36 destined for two individuals located in Iran. Zulutrade failed to screen or otherwise monitor its customer base for OFAC compliance purposes at the time of the apparent violations. This failure was the result of a lack of awareness regarding U.S. sanctions regulations.

How OFAC Determined the Penalty

OFAC determined that Zulutrade did not voluntarily self-disclose the apparent violations, and that the apparent violations constitute a non-egregious case. The base penalty for the apparent violations was $844,090,000. The settlement amount of $200,000 reflects OFAC's consideration of aggravating and mitigating factors pursuant to the General Factors under OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. part 501, app. A.

Aggravating Factors

Zulutrade acted recklessly in maintaining accounts for, and placing FX trades on behalf of, persons subject to U.S. sanctions without undertaking any measures to comply with OFAC regulations
Zulutrade, including its senior management, had reason to know of the conduct that led to the apparent violations
Zulutrade's actions caused harm to U.S. sanctions program objectives
Zulutrade did not have an OFAC compliance program in place at the time of the apparent violations

Mitigating Factors

Zulutrade is a small company with limited business operations
Zulutrade has taken remedial action in response to the apparent violations
Zulutrade has not received a penalty notice or Finding of Violation in the five years preceding the earliest date of the transactions giving rise to the apparent violations
Zulutrade substantially cooperated with OFAC's investigation

Zulutrade's OFAC settlement was coordinated with the Commodity Futures Trading Commission (CFTC), Zulutrade's primary regulator, which was concluding its own enforcement action against Zulutrade for violations of CFTC rules arising out of the same pattern of conduct. The CFTC coordinated with OFAC to ensure commitments by Zulutrade to enhance its sanctions compliance capabilities.

Compliance Takeaways

Zulutrade failed to screen or otherwise monitor its customer base for OFAC compliance purposes, and did not have an OFAC compliance program in place at the time of the apparent violations. This failure was the result of a lack of awareness regarding U.S. sanctions regulations. The CFTC coordinated with OFAC to ensure commitments by Zulutrade to enhance its sanctions compliance capabilities.

Official Source Documents

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Provided for informational purposes only and does not constitute legal or compliance advice. Always consult the source document directly rather than relying on this summary.

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Archived on June 13, 2026

SHA-256: 5035e1af1c8c61ec3be2bfb75c5901d04647f84b69b6e15d9281396b906706fd