US Software Company Discloses Possible Sanctions Breaches to OFAC
A financial software company recently disclosed to the Office of Foreign Assets Control that it may have violated U.S. sanctions by allowing its services to be used by customers in restricted countries.
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
California-based Bill Holdings -- which runs Bill.com, a site that offers invoicing software solutions -- said it recently found “gaps” in its internet protocol address blocking controls that may have caused possible violations. The company said it believes that some payments were made through its platform by U.S. customers traveling in sanctioned countries, according to its August SEC filing. It also said Zipbooks, a subsidiary that offers accounting software and online invoicing, “onboarded and received a limited amount of subscription payments from certain subscribers potentially located in sanctioned countries.”
The firm said it submitted a voluntary self-disclosure to OFAC in March, adding that it regularly scans its customers against denied party lists maintained by OFAC and other agencies to “monitor and mitigate these risks." If the company's "services are accessed from a sanctioned country in violation of the trade and economic sanctions," it said, "we could be subject to fines or other enforcement action.”
Although Bill Holdings recently “implemented additional controls and screening tools designed to prevent similar activity from occurring in the future,” the company said there “can be no assurance that we will not encounter similar issues with our sanctions compliance processes in the future.”
An OFAC spokesperson didn’t respond to a request for comment.