In Depth: Listen To Your Regulator On Sanctions And Crypto

It should come as no surprise that the crushing sanctions imposed on Russia in recent weeks will be met with efforts to evade their impact. From Russian firms starved for U.S. dollars to oligarchs starved for that new villa or yacht, some sanctions targets inevitably will attempt to access the capital, goods and services from which they have been severed so completely since Russia's invasion of Ukraine began. To do so, in most cases they will be forced to conceal their involvement in a transaction. Enter: crypto.

Almost immediately after Russia commenced hostilities against its neighbor, concerns were raised by pundits and policymakers that cryptocurrencies – by virtue of their decentralization and the anonymity they afford – could turbocharge efforts to evade the massive package of sanctions imposed on Russia. For example, in a March 2 letter, Senators Elizabeth Warren and Mark Warner wrote to Secretary of the Treasury Janet Yellen asking for information on how