Cloud-based services company discloses possible sanctions violations

In a regulatory filing on September 11, 2019 in anticipation of an initial public offering, San Francisco-based Cloudflare, Inc. disclosed that in May, 2019, it submitted a voluntary self-disclosure to the Office of Foreign Asset Controls of the US Department of the Treasury, in which it reported that some of its products were used by or for the benefit of individuals and entities included in OFAC’s Specially Designated Nationals and Blocked Persons list.  Cloudflare further disclosed that a small number of these parties made payments to the company in connection with use of the company’s platform.  Cloudflare added that its voluntary disclosure is under review by OFAC.

Form S-1

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