About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

1 1 (May 4, 2022)

handle is hein.crs/govefrl0001 and id is 1 raw text is: Congressional
*. Research Service
Russian Sanctions and Cryptocurrency
May 4, 2022
The United States has imposed sanctions against certain Russian entities and individuals in response to
Russia's invasion of Ukraine-including on virtual currency transactions and cryptocurrency mining.
Some Members of Congress and other observers have expressed concern that sanctioned parties may
evade sanctions using cryptocurrency to transfer funds out of Russia, convert rubles to other fiat
currencies, or receive payments and make purchases. Bills have been introduced in the 117th Congress to
prevent such evasion. This Insight focuses on various evasion techniques and potential gaps in existing
regulatory oversight.
Potential Sanctions Evasion with Cryptocurrency
Cryptocurrency transactions may enable sanctions avoidance, though there is limited public information
on the use of these methods.
Cryptocurrencies are created and exchanged through blockchain networks, which store tamper-resistant
records of transactions. Most cryptocurrency transactions between parties are recorded directly on public
blockchains-meaning anyone can view the records. Users are identified by public key addresses rather
than their real-world identities, which led to concerns that Russian actors may use the pseudonymity of
cryptocurrency to evade sanctions.
Cryptocurrency supporters argue that sanctions evasion is impossible because transactions are publicly
viewable on blockchains, which law enforcement may trace using analytics software and users' public
key addresses. Additionally, cryptocurrencies are not a widely accepted form of payment, so most users
convert to fiat currency (currency established by sovereign governments) through cryptocurrency
exchanges to make purchases. In the United States, many exchanges are required to maintain customer
identification programs and follow sanctions, which may limit evaders' ability to use exchanges that
comply with U.S. regulations.
However, sanctions evaders may attempt to obscure their blockchain transactions and evade measures
imposed by exchanges through the following practices:
 Chain-hopping is the process of converting one cryptocurrency into another to hide
illicit funds. In 2020, North Korean actors attempted to use chain-hopping to launder
stolen cryptocurrency and evade sanctions.
Congressional Research Service
https://crsreports. congress.gov
IN11920
CRS INSIGHT
Prepared for Members and
Committees of Congress

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Already a HeinOnline Subscriber?

profiles profiles most