This report by Observatoire ARGA and ARGA Atlas examines the legal and practical risks arising from the use of stablecoins and other digital assets in an environment of expanding sanctions regulation, compliance controls and international information exchange. It focuses on situations in which decisions by stablecoin issuers, cryptocurrency platforms, custodial service providers and public authorities lead to asset freezes, restrictions on access to funds and substantial property losses.

The authors show that stablecoins are not a fully autonomous instrument of financial freedom. Many are issued by centralized entities that retain the technical ability to freeze tokens, block addresses, comply with regulatory requirements and apply their own risk-assessment rules. A user may hold tokens in a wallet, but the practical ability to use them depends on contractual terms, sanctions rules, blockchain analytics and internal compliance procedures.

The report identifies key risks: the mistaken perception of stablecoins as uncontrollable assets, concentration of power in private companies, opacity of algorithmic risk assessments, sanctions-related restrictions without formal listing, confusion between technical and legal grounds for blocking, cross-border uncertainty and persistence of an adverse compliance profile after restrictions are lifted.

The report’s central conclusion is that stablecoins should be treated as regulated property assets, not as a fully autonomous form of capital. Effective protection of digital asset holders requires analysis of jurisdiction, contractual terms, sanctions risks, source of funds, technical data, blocking procedures and international standards for the protection of property rights.