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GDF Hubs

GBBC Digital Finance, together with its community of industry expert members, is driving the acceleration and adoption of digital finance to support the next era of digital commerce.

The GDF Sanctions Hub gathers key resources, tools, and guidance for sanctions and the crypto and digital asset industry.

Top Resources

Hogan Lovells Sanctions Navigator

The Sanctions Navigator provides a practical and straightforward overview of the key international ...
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Office of Foreign Assets Control (OFAC) Guida ...

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is committed to eng ...
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Latest

TRM Labs Sanctions Screening Tool

TRM Labs has launched a free API-based sanctions screening tool. In the wake of unprecedented ...
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Joint statement from UK Financial Regulation ...

The UK financial regulatory authorities reiterate that all UK financial services firms, including t ...
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Sanctions Tools

Chainalysis Sanctions Screening Tools  

Chainalysis have release new, free to use sanctions screening tools, making it easier for any organization to integrate sanctions screening for cryptocurrencies into their existing operation. "The inherent transparency of the blockchain can make cryptocurrency a powerful deterrent to sanctions evasion...Cryptocurrency compliance professionals with the right data and technology are effective at identifying transactions by sanctioned entities and taking action."

The solutions include:

  1. An API designed for web/mobile UIs and web servers: Users will receive an API key through which they can check if an address of interest is on the sanctions list or not
  2. An on-chain oracle designed for smart contacts: Users can call the Chainalysis oracle from another smart contract to check if an address is on a sanctions list. The Chainalysis oracle is deployed on most EVM chains like Ethereum, Avalanche, BSC, Polygon, Optimism, Arbitrum, Celo.

Hogan Lovells Sanctions Navigator

The Sanctions Navigator provides a practical and straightforward overview of the key international sanctions regimes. It allows you to assess key sanctions risks at a glance, evaluate the impact of sanctions on your business, and keep abreast of the latest developments by receiving insight and analysis from the Hogan Lovells International Trade team.

Considering the significant impacts that current Russian Sanctions developments have on our clients’ operations, access to the Sanctions Navigator is currently free of charge.

TRM Labs Sanctions Screening Tool

TRM Labs has launched a free API-based sanctions screening tool. In the wake of unprecedented sanctions on Russia, it is more important than ever that every crypto business - no matter size or maturity - has the ability to mitigate the risk of sanctions exposure. Users of the free tool will benefit from TRM’s unique cross-chain coverage, which spans 25 blockchains and enables users to be notified when a sanctioned address matches a corresponding address on multiple blockchains.

Crypto Industry Guidance On Sanctions

Building Sanctions-Ready Compliance Programs

Malcolm Wright led a discussion on the industry’s role in the crisis, and what actions might be taken. Panellists included Elaine Sun, Huobi, Bill Hughes, ConsenSys, Liat Shetret, Solidus Labs, and Che Sidanius, Refinitiv.

Chainalysis Guidance for Exchanges

With the Russian invasion of Ukraine ongoing and extensive sanctions being levied accordingly, cryptocurrency-specific designations may be close behind. Chainalysis outlines six steps that exchanges can take to strengthen compliance.

Elliptic’s Financial Crime Typologies In Cryptoassets: The Concise Guide for Compliance Leaders

Elliptic's concise guide for compliance leaders identifies key red flags to strengthen AML protocols associated with cryptoassets. This guide is for compliance leaders to assist cryptocurrency businesses in identifying specific money laundering and terrorist financing risks they may face, highlighting the key red flags to look out for to ensure you stay ahead of criminal actors to prevent crime associated with cryptoassets.

FinCEN Alert on Potential Russian Sanctions Evasion Attempts and Virtual Currencies

The Financial Crimes Enforcement Network (FinCEN) is alerting all financial institutions to be vigilant against efforts to evade the expansive sanctions and other U.S.-imposed restrictions implemented in connection with the Russian Federation’s further invasion of Ukraine. This alert provides select red flags to assist in identifying potential sanctions evasion activity and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations, including with respect to convertible virtual currency (CVC).

How could Russia Use Crypto to Evade Sanctions?

TRM Labs breaks down where the risks are, and how they can be mitigated.

Joint statement from UK Financial Regulation Authorities on Sanctions and the Cryptoasset Sector

The UK financial regulatory authorities reiterate that all UK financial services firms, including the cryptoasset sector, are expected to play their part in ensuring that sanctions are complied with. Read the full statement on legal and regulatory requirements for crypto and digital asset firms here.

Notabene Guidance on Sanctions

“In the absence of a SWIFT network for crypto, exchanges can take a more targeted approach to prevent transactions with sanctioned individuals. By leveraging sanctions screening providers and Travel Rule solutions, crypto exchanges can implement more effective hyper-targeted individual sanctions and avoid a possible blanket ban in a broader group of citizens.”

Explore Notabene’s guidance to actions that companies can take today – regardless of Travel Rule compliance status – to block transactions to sanctioned individuals.

OFAC FAQs on Virtual Currencies

Use the OFAC toolkit for frequently asked questions on virtual currencies and digital assets.

Office of Foreign Assets Control (OFAC) Guidance for Crypto Industry

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is committed to engaging with the virtual currency industry to promote understanding of, and compliance with, sanctions requirements and due diligence best practices. In October 2021, they released this guidance to assist the virtual currency industry in mitigating these risks.

You can find the OFAC Sanctions List Search tool here. https://sanctionssearch.ofac.treas.gov/

Parts of the GDF Code Referencing Sanctions

The GDF Code of Conduct is designed to establish a common understanding of the best practices and governance policies for the global digital asset market. 

Divided into 10 parts, the Code addresses each component of the digital finance value chain, and is written from the perspective of general global regulatory frameworks. The following is a summary of where and how sanctions are covered throughout the Code.

The Implication of Russian Sanctions: Preparing Your Compliance Teams

David Carlisle, Ellitpic, and Erin Colocillo, Block, discuss the recent major sanctions developments targeting Russia, the impact of targeted sanctions, and how compliance teams can identify high risk cryptoasset exchanges and other services that might enable sanctions evasion.

The US National Security Council Approach to Crypto and Sanctions 

Speaking at the GDF Emergency Summit, Carole House, Director of Cybersecurity and Secure Digital Innovation at the US National Security Council, gave an overview of the US sanctions. Below are the key messages.

Travel Rule, VASP Due Diligence, and Sanctions

Joseph Weinberg, co-founder of Shyft, highlighted three main points at the GDF Emergency Summit [link] on the Travel Rule and sanctions. Read more and watch the keynote here. 

TRM Talks Russia Sanctions with U.S. Government Officials

Watch the full video of the exclusive interview with senior U.S. government officials Carole House and Todd Conklin as they join TRM Talks to discuss Russia sanctions and the role, if any, of cryptocurrency.

TRM Talks Russia Sanctions with U.S. Government Officials: 5 key takeaways

In the midst of a steady drumbeat of escalating and unprecedented economic measures taken against Russia this week in response to its invasion of Ukraine, senior U.S. government officials Carole House and Todd Conklin joined TRM Talks to discuss Russia sanctions and the role, if any, of cryptocurrency.

General Resources On Sanctions

EU Sanctions Map

The European Union (EU) Sanctions Map was launched under the Estonian Presidency of the Council of the EU in 2017 to provide general up-to-date information on restrictive measures (sanctions) that are applicable in the EU jurisdiction, whether transposing measures imposed by the United Nations Security Council or implemented autonomously. This map does not provide information on national sanctions of the EU Member States or any other sanctions imposed by third states.

Global Sanctions Dashboard

See Atlantic Council's Sanctions Dashboard, as they review the current sanctions against Russia and the potential consequences the Kremlin may face. The resource also covers Iran’s sanctions ahead of negotiations in Vienna.

Refinitiv Overview of Explicit and Implicit Sanctions 

See Che Sidanius’s presentation on both explicit and implicit sanctions coverage, and Refinitiv®’s World-Check®, a risk intelligence database designed for use in due diligence and screening programs for anti-money laundering, sanctions, and anti-bribery and corruption compliance.

RUSI Overview of Targeted Russia Sanctions

Read through the slides from the RUSI presentation at the GDF Emergency Summit on Sanctions here, in which Anton Moiseienko sets out the difference between targeted and comprehensive sanctions, how sanctions against Russia have evolved over recent years, and the US’s approach to sanctions.

The UK’s Russia (Sanctions) (EU Exit) Regulations 2019 

Having left the EU, the UK released the Russia (Sanctions) (EU Exit) Regulations, ensuring that the sanctions regime continues post the UK’s exit from the EU, and allowing its own sanctions regime.

Industry Response To Ukraine Conflict

Coinbase’s Statement on Using Crypto Tech to Promote Sanctions Compliance

Read how Coinbase is leading the way in sanctions compliance, and leveraging technology to enhance their sanctions compliance efforts.

Crypto for Ukraine Dashboard

The crypto community has mobilised to respond to the crisis in Ukraine with donations. Track the latest in Merkle Science's public live tracker.

CTA: Crypto Compliance and Sanctions

Speaking at the GDF Emergency Summit on Sanctions, Ari Redbord, head of Legal and Government Affairs at TRM Labs, highlighted the industry's rallying cry to everything that we possibly can to ensure that crypto platforms are not used to evade sanctions. 

The Blockchain Community Response to the Ukraine Conflict

Crypto is playing an important role in the Ukrainian conflict, with users across the globe stepping up to help in ways big and small. At the GDF Emergency Summit on Sanctions, GBBC CEO and GDF Board Members Sandra Ro shared some of the encouraging stories of the crypto community’s response to the emerging crisis.

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