This report has been prepared by Observatoire ARGA and is devoted to a comprehensive analysis of the role of stablecoins—primarily USDT—and the TRC-20 network in the formation of a modern parallel financial infrastructure, widely used in grey and illegal transnational schemes. The study focuses on the transformation of stablecoins from auxiliary tools of the crypto market into key elements of alternative payment circuits operating outside the traditional banking system and institutional control mechanisms.

The report examines in detail the technological, economic, and legal factors that have led to USDT’s dominant position in cross-border settlements, investment fraud, money laundering, circumvention of currency and sanctions restrictions, and informal capital flows via the OTC segment and P2P channels. Particular attention is given to the TRC-20 network, which—due to low fees, high transaction speed, and weak integration with supervisory mechanisms—has effectively become the infrastructural basis for mass stablecoin use in grey and black financial schemes.

A separate section of the report analyzes the institutional gap between the architecture of stablecoins and existing financial oversight models. It demonstrates that traditional compliance approaches (AML/KYC), focused on centralized intermediaries and entry points to the financial system, are ineffective in a decentralized infrastructure, non-custodial wallets, and OTC conversion contexts. This generates the illusion of control while systemic monitoring of key capital flows is effectively absent.

The report also analyzes law enforcement limitations related to the absence of a single responsible entity within the stablecoin ecosystem, the fragmented nature of international regulation, and asymmetries in interaction between digital asset issuers and enforcement authorities. It emphasizes that the formal ability to freeze assets does not translate into a predictable and universal mechanism to protect victims’ rights or prevent abuses.

Significant attention is given to the political-economic context of stablecoin use, including their role in corporate conflicts, asset redistribution, sanctions-sensitive cases, and quasi-criminal proceedings, where digital assets become tools for covert control over property and financial flows. In such situations, criminal-law forms may be used to legitimize economic objectives, substantially complicating legal classification and international cooperation.

The concluding section formulates findings on the systemic nature of risks associated with stablecoin use and provides recommendations for adapting international and national regulatory mechanisms to the new reality of digital payment instruments. In particular, it highlights the need to develop unified stablecoin regulatory standards, strengthen oversight of the OTC segment, and harmonize supervisory regimes for digital and traditional payment systems.