In December, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (“Paxful”), pursuant to a consent order.

Paxful is an exchanger of convertible virtual currencies (“CVC”), operating both a CVC wallet service and a marketplace for peer-to-peer (“P2P”) buyers and sellers of CVC.