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handle is hein.crs/govefvi0001 and id is 1 raw text is: Congressional
* Research Service
Russia Sanctions and Cryptocurrencies: Policy
Issues
May 26, 2022
The G-7 (Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States), the
European Union (EU), and other countries have responded to Russia's expanded invasion of Ukraine in
February 2022 with swift, coordinated, and broad sanctions designed to exert significant pressure on key
Russian individuals and companies, as well as the broader Russian economy. As the multilateral coalition
seeks to sustain economic pressure on Russia, and Russia seeks ways to mitigate the impact of sanctions,
some in Congress are asking whether cryptocurrencies offer Russia a way to evade sanctions.
This Insight discusses related policy issues and proposed legislation; for technical analysis of
cryptocurrency as a potential means of sanctions evasion, see CRS Insight IN 11920, Russian Sanctions
and Cryptocurrency, by Kristen E. Busch and Paul Tierno.
Are Transactions in Cryptocurrencies Subject to Sanctions?
The United States and G-7 partners have reiterated that sanctions apply to all transactions involving
designated parties, regardless of the currency in which a transaction is denominated or the means used to
complete a transaction. U.S. sanctions apply equally to transactions conducted in traditional fiat
currencies (e.g., dollars, yen, euros, pounds, renminbi) and transactions conducted in cryptocurrencies or
other digital currencies.
Is Russia Evading Sanctions with Cryptocurrency?
The pseudonymous nature of cryptocurrency may facilitate illicit finance by making payments more
difficult to trace. However, the Treasury Department has found little evidence to date that Russian
government officials or Russian individuals are using digital currencies to evade sanctions. Analysis by a
private-sector blockchain analytics firm reached the same conclusion. More generally, the global
cryptocurrency market is not liquid enough to backfill the financial needs of the entire Russian economy,
the 1 1th largest in the world before the 2022 war. The collapse in the cryptocurrency market in May 2022
also highlights the volatility risk reliance on cryptocurrencies poses for would-be sanction evaders.
Reasons for concern remain. The cryptocurrency market is likely liquid enough to allow some Russian
individuals and companies to transfer large sums of money. Actors associated with robust sanctions
Congressional Research Service
https://crsreports.congress.gov
IN11939
CRS INSIGHT
Prepared for Members and
Committees of Congress

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