‍Key takeaways

• The EU’s 20th sanctions package imposed a blanket prohibition on all crypto asset transactions with any crypto asset service provider established in Russia and Belarus — a shift from targeting individual platforms to banning the entire Russia and Belarus-based crypto-asset service provider (CASP) ecosystem.
• The EU explicitly cited the ineffectiveness of individual designations, noting that further listings would result in new successor platforms. This reflects recognition of actions like the Garantex-to-Grinex migration, where sanctioned operators launched a near-identical replacement within months of the original platform’s seizure.
• The A7A5 stablecoin, which served as the financial bridge between Garantex and Grinex,…