Enhancing the EU Response to Crypto-Enabled Sanctions Circumvention
To disrupt Russia’s sanctions-evasion networks, the EU must target the infrastructure that allows for widespread use of crypto: liquidity, convertibility and access to the formal economy.

Crypto is no longer a peripheral feature of sanctions evasion. Nor is it a self-contained world of wallets, tokens and exchanges that can be addressed separately from the wider architecture of illicit finance. For Russia, Iran and other sanctioned actors, crypto-assets are increasingly embedded in broader systems of procurement, payment, settlement and value transfer. They are used alongside the traditional suite of tools favoured by sanctions evaders, including shell…





