Russia–Ukraine Conflict Increases Regulatory Risks For Sanctions Evasion Through Crypto-Based Transactions

In response to Russia's invasion of Ukraine, the United States and dozens of its allies and partners around the globe have imposed what the White House has called "the most impactful, coordinated, and wide-ranging economic restrictions in history."¹ Although Russia is still not subject to a complete embargo in the United States, the sanctions placed on Russia have been severe and targeted against individuals and entities ("persons") operating in some of its most important sectors, such as the financial sector.² Under U.S. sanctions, for example, several key Russia-based financial institutions—including Russia's largest bank—and certain Russian elites (also known as "oligarchs") are now blocked, meaning their assets within the United States or in possession or control of U.S. Persons³ are now "frozen." Furthermore, several top Russian banks have been banned from the Society for Worldwide Interbank Financial Telecommunication ("SWIFT")—a critical messaging system used