Secondary Sanctions and Export Restrictions in the Crypto Economy: How Digital Assets Fall Under Extraterritorial Control and Who Bears the Risks
This report provides a systematic analysis of the mechanisms through which secondary sanctions and export controls are extended to the digital finance sector. The research focuses on the extraterritorial nature of sanction regimes that impact not only direct transaction participants but also infrastructure intermediaries, including exchanges, stablecoin issuers, and software developers. The author details the expansion of the “facilitator” category, the risks of sudden asset freezes for international businesses, and the issue of “private enforcement,” where access restriction decisions are made by commercial platforms outside of judicial procedures. The report reveals how the integration of the crypto economy into the sphere of global geo-economic control fragments the market and forces participants to seek workarounds in less transparent segments.
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