Circumvention of International Sanctions Using Cryptocurrency Infrastructure: Mechanisms, Risks, and Limits of Law Enforcement

This report has been prepared by Observatoire ARGA and is devoted to a systematic analysis of the use of cryptocurrencies and related infrastructure for the purpose of circumventing international sanctions regimes. The study examines how the development of decentralized digital financial instruments has transformed the traditional logic of sanctions pressure, which was historically based on control over banking settlements, correspondent accounts, and financial intermediaries.

The report demonstrates that cryptocurrencies have ceased to be a supplementary or marginal tool and have evolved into a stable alternative settlement environment that enables the preservation of liquidity, the transfer of value, and the concealment of economic relationships outside the classical financial system. Particular attention is paid to the economic logic of sanctions circumvention, within which digital assets are used to neutralize the core effects of sanctions—asset freezes, restrictions on cross-border transfers, and denial of access to international capital markets.

Separate sections address the role of stablecoins, primarily USDT, which—due to their peg to fiat currencies, high liquidity, and minimal transaction costs—effectively perform the function of quasi-banking money under conditions of sanctions pressure. The significance of the TRC-20 network is analyzed as a low-threshold infrastructure enabling mass adoption of stablecoins through high transaction speed, extremely low fees, and limited external monitoring outside centralized platforms.

A substantial part of the report is devoted to the over-the-counter (OTC) segment and the role of informal intermediaries that facilitate the conversion of fiat funds into cryptoassets, cash withdrawals, and the transfer of economic control without transparent on-chain traces. It is emphasized that the OTC market constitutes one of the key institutional gaps in the sanctions control system.

The report also analyzes the use of non-custodial wallets, mixers, and cross-chain operations as tools for data fragmentation and concealment of fund origins. It is shown that the distribution of asset control across multiple addresses, proxy structures, and technical intermediaries significantly reduces the evidentiary value of blockchain analytics and complicates the identification of ultimate beneficial owners.

Special attention is given to the limitations of existing sanctions compliance mechanisms and international law enforcement. The report examines issues of territorial jurisdictional fragmentation, the absence of unified international standards, asymmetries in interaction between digital asset issuers, platforms, and law enforcement authorities, as well as the delayed and reactive nature of current control measures.

The concluding section highlights the political-economic dimension of sanctions circumvention through cryptocurrencies, including their role in asset redistribution, preservation of economic influence, and maintenance of cross-border business relations under restrictive regimes. The report formulates conclusions regarding the systemic nature of the identified risks and offers recommendations aimed at developing international standards for sanctions control in the cryptocurrency sphere, strengthening regulation of the OTC segment, and harmonizing compliance approaches between traditional and digital financial systems.