On Friday, the Biden administration announced that it would likely go after Russian crypto exchanges in the wake of Ukraine’s invasion as part of its latest efforts to impose additional sanctions against the nuclear power.
According to a Biden administration official, imposing sanctions on Russia’s crypto activities would need to be done in a way that wouldn’t harm the broader crypto market – which could also make imposing them difficult.
Up and until now, the U.S. has resorted to punitive economic measures in efforts to hold Russia accountable for its actions, including targeting the country’s financial sector, big corporations, government officials, members of the elite, and the Nord Stream 2 natural gas pipeline – however, after the U.S. and its European allies reached a consensus, cutting off certain Russian banks from Swift was the next move.
The U.S. has gone after crypto in geopolitical affairs before
Imposing crypto sanctions, however, is not straightforward, since digital currencies are by nature borderless, private, and beyond the reach of most governments.
The administration has previously gone after Russian exchanges before, where in September 2021, the Biden administration blacklisted Russian-owned cryptocurrency exchanges SUEX OTC for allegedly helping launder ransomware payments.
In the following month, the U.S. Treasury Department also sanctioned Chatex, another Russian-owned cryptocurrency exchanged that “facilitated transactions for multiple ransomware variants” and provided a link back to SUEX OTC for its ransomware activities.
Chatex operates its crypto exchange and wallet through a Telegram messaging bot. Chatex has since been added to the Treasury’s Office of Foreign Asset Control’s (OFAC) “Specially Designated Nationals” list which blacklists the exchange, preventing U.S. citizens from doing business with it, as well as the blockage of any individual assets held on the exchange.
The Biden administration’s crackdown on ransomware follows a Chainalysis report that estimated over $131 million in payments sent to ransomware-linked addresses between July 2020 and June 2021 – more than double what Western Europe has experienced as the second hardest-hit region.
Nearly 74 percent of global ransomware revenue ($400 million in cryptocurrency) went to entities that were probably affiliated with Russia in some way, according to a Feb. 14 report by Chainalysis.
Could Russia’s affluent still avoid these sanctions?
With the Biden administration’s latest interest in taking on cryptocurrency firms that transact with blacklisted Russian banks, such as VTB and Sberbank, there’s an argument to be made that Russia and its affluent citizens could potentially circumvent any U.S. sanctions by holding onto their wealth in Bitcoin as well as making investments to other countries and parties that want to continue transacting with them.
And it’s not unheard of where other countries look for workarounds while under Western sanctions – looking back to Iranian citizens soliciting crypto donations for flood victims in 2019 while under U.S. sanctions, while also using revenue from its Bitcoin mining to continue selling oil.
Back in 2020, Venezuelan President Nicolas Maduro proposed a bill that attempted to use crypto to evade different forms of sanctions imposed on the country.
Earlier this month, independent sanctions monitors informed the U.N. Security Council that North Korea was using cryptocurrencies to avoid ongoing sanctions in efforts to fund its nuclear and ballistic missile program.
Indeed, the U.S. president’s desire to potentially target Russia through crypto may not be as well thought out as hoped, given that a recent report by the Russian government suggests that there are over 12 million cryptocurrency wallets in the country, which collectively, hold over $23.9 billion.
“Russia has had a lot of time to think about this specific consequence,” said Michael Parker in an interview with The New York Times. Parker is a former federal prosecutor who now heads the anti-money-laundering and sanctions practice at the Washington law firm Ferrari & Associates.
“It would be naïve to think that they haven’t gamed out exactly this scenario.”
The purpose of the potential crypto sanctions is to disrupt the economic landscape, according to an official from the Biden administration.
The administration would need to find a way to disadvantage Russia, but not at the expense of the broader market, which may not be easy. From the Putin administration’s perspective, cryptocurrencies could be used to offset the effects of other imposed sanctions.
Seeing that banks and financial institutions are required by abide by KYC, or know-your-customer rules, exchanges aren’t as in-depth as they could be, despite the ongoing need to implement KYC and flag suspicious transactions. Exchanges like Coinbase and Binance often work with regulators in different areas of reporting, in conjunction with FinCENs requirement that “money transmitters” register under the Bank Secrecy Act.
In DAOs we trust?
Ukraine, on the other hand, ranked fourth on the Chainalysis Global Crypto Adoption Index – behind Vietnam, India, and Pakistan.
With a tech pool of over 200,000 workers, the country regulated many cryptocurrencies last year, including bitcoin. Illia Polosukhin, co-founder of Ukrania’s NEAR protocol and an Ethereum competitor, noticed that Tether had grown in popularity due to its status as a reserve currency in Ukraine.
According to a recent report by blockchain analytics firm Elliptic, the government has raised $9.9 million in cryptocurrency donations at the time of going to press, through two DAOs – demonstrating how the trustless entity can be used for good.
Ultimately, what the Biden administration wants to do proves to be extremely difficult and challenging to implement, even if the OFAC continues to police the ongoing sanctioning efforts.
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