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Global 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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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.

Notabene Sanctions Screening Tool

Notabene has launched a sanctions screening tool in partnership with Refinitiv for Financial Action Task Force mandated counterparty screening during Travel Rule transactions, allowing Notabene customers to automatically screen counterparties to the crypto transactions processed on their platform. This interception can also be applied to incoming transactions–VASPs can stop or reject transfers coming from high-risk individuals.

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.

Challenges and Opportunities in Cryptocurrency Sanctions Compliance and How Blockchain Analysis Can Help

Andrew Fierman, Head of Sanctions Strategy at Chainalysis, breaks down the fundamental elements of crypto sanctions compliance, including Know Your Customer (KYC), transaction monitoring, continuous data improvements, taking context into account, and industry coordination. In addition, Fierman provides comparisons between TradFi and crypto to show the unique challenges and opportunities presented to those developing sanctions compliance programs in crypto.

Cryptoassets and sanctions: How easy is it to freeze cryptoassets?

Global law firm Norton Rose Fulbright provides an overview of legal and regulatory requirements, presenting information on the English approach to freezing cryptoassets in a litigation context.

Cryptocurrency Sanctions: 6 Steps for Exchange Compliance

Amidst Russia's invasion of Ukraine and sanctioned being levied accordingly, Chainalysis outlines six steps exchanges can take to strengthen compliance.

Elliptic’s Typologies Report: Preventing Financial Crime in Cryptoassets

Elliptic provides a guide for compliance leaders in identifying specific money laundering and terrorist financing risks, developing anti-money laundering and counter terrorist financing (AML/CTF) governance systems, and evolving the controls in place to manage risk to business, customers, and society amidst the development of the "metaverse".

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).

Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Financial Facilitators

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on ten key Hamas terrorist group members, operatives, and financial facilitators in Gaza and elsewhere including Sudan, Türkiye, Algeria, and Qatar. In October 2023, OFAC published this press release outlining the designations which seek to target members managing assets in a secret Hamas investment portfolio, a Qatar-based financial facilitator with close ties to the Iranian regime, a key Hamas commander, and a Gaza-based virtual currency exchange and its operator.

GBBC Digital Finance’s Sanctions Working Group: Report on Cryptoassets and Sanctions Compliance

Amidst the Russian invasion of Ukraine, discussions have been on the rise on whether cryptoassets could play a role in enabling sanctions evasion. In response, GBBC Digital Finance's Sanctions Working Group put together a report to facilitate an informed policy discussion about cryptoassets and sanctions. This report presents a concise overview including information on the current state of regulatory and legal requirements, sanctions compliance practices by the industry, sanctions evasions risks, and policy recommendations.

How could Russia Use Crypto to Evade Sanctions?

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

How Hamas has utilized crypto, and what may be coming

This article covers the history of Hamas's use of crypto and how compliance teams at crypto exchanges can help identify and disrupt terror financing.

How Hamas Uses Crypto

TRM Labs breaks down how Hamas uses crypto and how US and Israeli authorities have targeted their use of crypto.

Implementing a Sanctions Compliance Program for Digital Assets

Ari Redbord, TRM Labs, led a discussion on OFAC enforcement actions and expectations for crypto businesses' sanctions compliance programs. Panellists include Dallas Woodrum from OFAC, Isabella Edmonds from GeoComply, and Eric Lorber fom PwC.

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 Sanctions Counterparty Risk Management

Notabene provides an overview on how sanctions have affected the crypto industry and how to comply with Financial Action Task Force mandated Travel Rule. In addition, Notabene includes guidance on 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.

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.

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: US and G7 allies target Russia’s evasion and procurement networks

See Atlantic Council's Sanctions Dashboard, as they recap the sanctions packages against Russia released ahead of the G7 Summit, review how the United States is tackling export controls circumvention and what should improve moving forward, explore the enforcement and effectiveness of the oil price cap, and discuss the failure of the US sanctions policy towards Sudan and how to fix it.

Global Sanctions Dashboard: What’s coming in 2023?

See Atlantic Council's Sanctions Dashboard, as they walk through the Fall 2022 sanctions against Russia and Iran, explain the implications of US semiconductor export controls against China, and show the projected sanctions trends in 2023.

Hogan Lovells Standards Mapping

See Hogan Lovells's interactive map on the legal and regulatory developments in AML and sanctions standards globally.

New package of EU sanctions against Russia

A summary of the latest package of sanctions against Russia, press release on 23 June 2023.

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.

US and global sanctions enforcement and compliance expectations for digital currencies

See DLA Piper's overview of the U.S. sanctions enforcement efforts and compliance expectations in relation to the crypto industry.

Sanctions News

FinCEN’s order regarding Bitzlato and action to be taken by financial institutions

Coinfirm provides compliance guidance following FinCEN's order, including determining whether the addresses they or their users transact with have nexus to Bitzlato, as well as advice on how to identify such addresses and where obliged entities’ AML processes and procedures Coinfirm’s solution fit.

Hamas Struggles To Earn Crypto But Raises Money In Other Ways

This article provides a breakdown on how Hamas fundraises and authorities have leveraged on blockchain technologies to stop these fundraising activities.

Iran’s Crypto Economy as a Sanctioned Jurisdiction

TRM Labs provides insight on Iran's crypto economy with a section on Iran as a sanctioned jurisdiction, including comparisons to other internationally sanctioned jurisdictions such as Russia.

OFAC and South Korea’s Ministry of Foreign Affairs Sanction Entities Associated with North Korean Hacking and IT Worker Crypto Payment Schemes

Chainalysis reports on OFAC and South Korea's Ministry of Foreign Affairs sanctions on four entities and one individual for their role in North Korean hacking activity and for helping North Korean IT professionals find contract work overseas to fund weapons proliferation.

OFAC Sanctions Dubai-based Financial Services Firm and CEO for Role in Russian Sanctions Evasion, Includes Crypto Address as SDN Identifier

Chainalysis provides updates on OFAC's sanctions on 22 individuals and 104 entities operating in 20 countries for their role in facilitating Russian sanctions evasion.

OFAC sanctions individuals, entities, and crypto wallets associated with North Korean cyber activities

TRM Lab updates on OFAC and South Korea's sanctions on North Korea-associated individuals, entities, and crypto wallets.

South Korea’s Ministry of Foreign Affairs Sanctions North Korea Hacking Group Kimsuky, Identifies Related Crypto Addresses

Chainalysis writes on South Korea's sanctions on a North Korean hacking group, as well as the collaboration between South Korea's Ministry of Foreign Affairs, National Intelligence Service, National Police Agency, and the U.S.'s FBI, Department of State, and National Security Agency to issue a joint advisory on related North Korean cyber espionage activities.

The Shutdown of Hydra

Ian Andrews, CMO at Chainalysis, Kimberly Grauer, Director of Research, Ian Gray, Senior Director, Research & Analysis at Flashpoint Intel, and Vlad Cuiujuclu, Team Lead, Global Intel, discuss the shutdown of Hydra by German authorities with assistance from U.S. law enforcement, as well as the U.S. government's sanctions on Hydra.

U.S. Authorities Move Against High-Risk Exchange Bitzlato for Providing Money Laundering Services to Ransomware Attackers and Other Russia-based Criminals

Chainalysis writes on FinCEN's order identifying Bitzlato as a primary money laundering concern over illicit Russian financing, which prohibits covered financial institutions from transacting with Bitzlato and its corporate officers.

Industry Response To Ukraine Conflict

A Year into Russia’s War on Ukraine, Cryptocurrencies Continue to Play a Key Role

A year since Russia's invasion of Ukraine, Chainalysis reflects on the significant role cryptocurrency has played in the Russia-Ukraine War, whether in the form of malicious activity like ransomware attacks and sanctions evasion, or more positive use cases like facilitation of donations to those in affected areas.

Chainalysis Podcast: Can Russia Use Cryptocurrency to Evade Sanctions?

Ian Andrews, CMO at Chainalysis, Kim Grauer, Director of Research, and Salman Banaei, Head of Public Policy for North America, discuss whether cryptocurrency could be the way that illicit actors move their fortunes out of Russia without access to the SWIFT network.

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. 

How 2022’s Biggest Cryptocurrency Sanctions Designations Affected Crypto Crime

Chainalysis looks at how the U.S. government’s crypto-related sanctions strategy has evolved over time, examines the types of entities that it has sanctioned so far, and analyzes the impact of those sanctions on the entities themselves and the wider crypto crime ecosystem.

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.

The First Crypto War? Assessing the Illicit Blockchain Ecosystem One Year Into Russia’s Invasion of Ukraine

A year since Russia's invasion of Ukraine, TRM Labs explores the state of the illicit crypto ecosystem over the past year, discussing how cybercriminals have adjusted their organization and tactics to adapt to the ongoing financial, political and logistical disruptions facing Europe and the wider world.

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.

Previously on the Sanctions Hub

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.

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.

Get in touch

Share with us any of your key resources and guidance to add to the Sanctions Hub