The European Commission has said cryptocurrencies are captured by targeted sanctions adopted by the EU in response to the conflict in Ukraine—as well as Belarus’ role in facilitating Russia’s invasion of Ukraine. 

“For Belarus, the measures introduce SWIFT prohibitions similar to those in the Russia regime, clarify that crypto assets fall under the scope of ‘transferable securities’ and further expand the existing financial restrictions by mirroring the measures already in place regarding Russia sanctions,” said the Commission. 

The Commission also “confirmed the common understanding that loans and credit can be provided by any means, including crypto assets, as well as further clarified the notion of ‘transferable securities,’ so as to clearly include crypto assets, and thus ensure the proper implementation of the restrictions in place.”

What do these sanctions do? 


The Commission’s new measures impose restrictions on 160 individuals, including 14 oligarchs and businesspeople involved in key Russian economic sectors. 

In Belarus, these measures restrict the provision of SWIFT to several key Belarusian banks and prohibit transactions with the Central Bank of Belarus. 

What’s more, these restrictions prohibit the listing and provision of services in relation to shares of Belarus state-owned entities on EU trading venues (as of April 12, 2022), prohibit the provision of euro-denominated banknotes to Belarus, and “significantly limit” the financial inflows from Belarus to the EU. 

When it comes to Russia, the amended measures introduce new restrictions on maritime navigation and radio technology exports. It also adds the Russian Maritime Register of Shipping to the list of state-owned enterprises subject to restrictions. 

Of course, these sanctions build upon an already widespread and sweeping list of sanctions applied by not only the EU, but the United States, the United Kingdom, and others. 


Sanctions have also hit the Central Bank of Russia, key political Russian officials, and much of the Russian State Duma—one of the chambers of the Russian parliament. 

Trade and investment restrictions are also in place in Donetsk and Luhansk. 

Sanctions and the role of crypto

This is not the first time the crypto industry has been cited as a potential means of sanctions evasion for Russia—or Belarus for that matter. 

In the wake of Russia’s invasion of Ukraine—which began on February 24, 2022—a plethora of public officials ranging from the Ukrainian Vice Prime Minister to the Japanese financial services regulator have turned their attention to this risk. 

France’s Finance Minister, Bruno le Maire, also recently said the EU was “taking measures” to ensure Russia doesn’t evade sanctions using crypto. 

In the United States, the U.S. Treasury recently announced new rules that built on an existing executive order to crack down on cryptocurrency-related efforts to evade sanctions. These rules take aim at “deceptive or structured transactions or dealings to circumvent any United States sanctions, including through the use of digital currencies.” 

Last October, the Treasury also took aim at this issue, publishing a report that said cryptocurrencies could undermine the broader American sanctions regime. 

All of this concern surrounds the multiple ways in which cryptocurrencies can help facilitate sanctions evasion. One such method is through the use of ransomware—an illicit industry that Russia profited from more than any other nation-state in 2021, per Chainalysis research


Crane Hassold, former FBI agent and current Director of Threat Intelligence at Abnormal Security, recently told Decrypt cryptocurrencies were the “primary factor” driving today’s ransomware industry. 

Elsewhere, Russia may pivot to Bitcoin mining—which President Putin has previously said Russia has a “competitive advantage” in—or the use of non-compliant exchanges, a strategy that Russian criminals have used before. 

“We’ve seen instances before of crypto asset exchange services that were complicit in enabling Russia-based criminals to launder large amounts of money…one was called SUEX,” said David Carlisle, Director of Policy and Regulatory Affairs at blockchain analytics firm Elliptic during a recent online webinar. 

In September 2021, the U.S. Treasury’s Office of Foreign Assets Control sanctioned SUEX pursuant to Executive Order 13694, which authorized the imposition of sanctions on those complicit in cyber-related activity against the interests of the United States. 

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